Good news and bad for primary care in 2024 Medicare physician payment proposal

The Centers for Medicare & Medicaid Services (CMS) released its proposed rule on the 2024 Medicare physician fee schedule and Quality Payment Program last week.

First, the bad news: CMS proposes to decrease the conversion factor (i.e., the amount Medicare pays per relative value unit, or RVU) to $32.75. That’s a drop of $1.14, or 3.34%, from this year’s rate. This is due to partially expiring conversion factor relief enacted by Congress as well as budget neutrality adjustments.

On the plus side, CMS proposes to make add-on code G2211, for office/outpatient evaluation and management (E/M) complexity, separately payable for dates of service on or after Jan. 1, 2024. (The code was initially slated to be payable in 2021, but Congress delayed that in a budget bill. It is currently a “bundled” code, meaning physicians may bill for it with other codes, but they will not receive separate payment.)

The change comes after advocacy by the American Academy of Family Physicians, and should result in increased payments for some of the services family physicians provide most. In its press release on the proposed rule, CMS framed it as a win for primary care, stating, “Primary care is instrumental in the delivery of high-quality, whole-person care. CMS is recognizing the value and inherent complexity in primary and longitudinal care by proposing to implement new payment and coding to accurately and appropriately pay for these services, which aligns with the goals articulated in the HHS Initiative to Strengthen Primary Care.”

CMS also proposes to:

• Pay telehealth services reported with place of service (POS) 10 (“telehealth provided in patient’s home”) at the non-facility rate, which means they’ll be paid the same as if provided in-person in the office. Services reported with POS 02 (“telehealth provided other than in patient’s home”) would be paid at the lower facility rate.
• Increase the work RVUs for general behavioral health integration care management (code 99484) and establish new G-codes for behavioral health crisis services furnished in any non-facility POS other than the physician’s office.
• Renew the additional payment for at-home COVID-19 vaccination and extend it to other Part B-covered vaccines (pneumococcal, influenza, and hepatitis B). The additional payment is limited to once per home visit even if multiple vaccines are administered, but Medicare will still provide an administration payment for each vaccine given.
• Add an optional social determinants of health (SDOH) risk assessment to the Medicare Annual Wellness Visit (AWV). To be eligible for an additional payment, physicians must deliver the SDOH risk assessment the same day as the AWV using a standardized, evidence-based tool that aligns with the beneficiary’s educational, developmental, and health literacy needs, while also being culturally and linguistically appropriate. CMS proposes to establish a standalone G-code to report SDOH risk assessment in conjunction with the Medicare AWV.

For more information, see the CMS:

• Press Release
• Fee Schedule Fact Sheet
• Medicare Shared Savings Program Fact Sheet

The American Academy of Family Physicians also has a more detailed summary of the rule available.  

— Kent Moore, AAFP Senior Manager for Payment Strategies

Posted on July 21, 2023