Additional Details
Reimbursement Updates
- CMS is finalizing a CY 2024 conversion factor of $32.74, which is 3.4% less than the CY 2023 conversion factor of $33.89. Similar to the conversation factor decrease experienced in 2023, this reduction continues to reflect the expiration of the statutory payment increase and budget neutrality adjustments.
Coding and Coverage
- Caregiver Training Services: CMS is finalizing its proposal to provide payment when practitioners (including physicians, nonphysicians, and therapists) train and involve caregivers to support patients with treatment plans for certain diseases and illnesses, such as dementia.
- Services for Health-Related Social Needs: To better account for resources needed to provide multidisciplinary support, CMS is finalizing its proposal to pay separately for Community Health Integration (CHI), Social Determinants of Health (SDOH) Risk Assessment, and Principal Illness Navigation (PIN) Services.
- CMS is also finalizing the addition of the SDOH risk assessments to annual wellness visits as an optional element with additional payments and no patient coinsurance or deductible. Further, CMS is finalizing proposed codes and payments for these risk assessments to occur on the same day as an E&M visit.
- Add-On Payment for E&M Services:Beginning January 1, 2024, CMS is finalizing proposed implementation of a separate add-on payment for HCPCS code G2211 (prolonged office/outpatient E&M services) to better account for the cost of providing longitudinal and chronic condition care services.
- Of note, implementation of this add-on payment has redistributive impacts for other CY 2024 payments under the PFS, due to statutory budget neutrality requirements.
- Split/Shared E&M Visits: For CY 2024, CMS is finalizing a revision to the definition of the “substantive portion” of a split (or shared) visit to include revisions to the CPT guidelines. Specifically, for Medicare billing purposes, the substantive portion reflects more than half of the total time spent by the physician or nonphysician practitioner, or a substantive part of the medical decision-making. Of note, CMS implemented public comments that requested the definition account for time spent in visits and/or in medical decision-making.
- Telehealth Service Flexibility: CMS is finalizing several proposals to continue providing practitioners with flexibility around how telehealth can be furnished, at least until the end of 2024. This includes finalizing the:
- Proposal to add health and well-being coaching services to the list of covered Medicare telehealth services on a temporary basis for CY 2024 and the addition of SDOH risk assessments on a permanent basis.
- Proposal to implement nonfacility PFS rate for telehealth services furnished to people in their homes.
- Continuation of the direct supervision definition to permit the presence of a supervising practitioner through live audio and video interactive telecommunications through December 31, 2024.
- Policy to continue allowing teaching physicians to use audio/video real-time communications technology to be present when a resident furnishes telehealth services in residency training locations through the end of CY 2024.
- Implementation of several provisions mandated by the Consolidated Appropriations Act (CAA) of 2023, including but not limited to temporary expansion of originating telehealth sites, expansion of the definition of telehealth practitioners, and continued payment for telehealth services furnished by Rural Health Clinics and Federally Qualified Health Centers.
- Behavioral Health Services:
- To implement provisions from the 2023 CAA, CMS is finalizing its proposal to provide MFTs and MHCs Medicare Part B coverage and payment under the PFS. CMS is also finalizing corresponding changes to behavioral health integration codes to allow MFTs and MHCs to bill for services.
- Also included in the CAA, CMS is finalizing its proposal to establish new HCPCS codes for psychotherapy crisis services that are furnished in an applicable site of service (any place of service where the nonfacility rate for psychotherapy for crisis services applies, other than the office setting, including the home or a mobile unit). Payment for these crisis services will be equal to 150% of the fee schedule amount for nonfacility sites of service for each year.
- CMS is also finalizing its proposal to allow Health Behavior Assessment and Intervention (HBAI) services (CPT codes 96156, 96158, 96159, 96164, 96165, 96167, and 96168) to be billed by clinical social workers, MFTs, MHCs, and clinical psychologists.
- CMS is also finalizing its proposal to modify the requirements for the hospice Conditions of Participation (CoPs) to allow social workers, MHCs, or MFTs to serve as members of the hospice’s interdisciplinary group (IDG).
- Finally, CMS is finalizing its proposal to apply an adjustment to the work RVUs for psychotherapy codes payable under the PFS, which CMS will implement over a four-year transition period. In response to public comments, CMS is also finalizing the application of this adjustment to psychotherapy codes that are billed with an E&M visit and to the HBAI codes.
- Opioid Treatment Programs (OTPs): CMS is finalizing its proposal to extend current flexibilities to allow for assessments furnished via audio-only telecommunications through the end of CY 2024.
Other Updates
- Medicare Part B Payment for Preventive Vaccine Administration: Effective January 1, 2024, CMS is extending the additional payment for in-home COVID-19 vaccine administration to pneumococcal, influenza, and hepatitis B vaccines administered in the home.
- Expanded Diabetes Screening: CMS is finalizing its proposal to expand coverage of diabetes screening to include the hemoglobin A1c (HbA1c) test, to simplify and expand frequency limitations, and to remove the specific clinical test criteria from the codified definition of “diabetes” for screening.
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Edited by: Matt Maslin
Published November 2, 2023
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