The CMS Physician Proposed Rule for 2024 is a pivotal development in healthcare. It outlines potential changes in reimbursement rates, telehealth expansion, and quality reporting requirements. Physicians must stay informed and engage in the comment period to influence the final rule. This rule can shape the future of healthcare delivery, impacting both providers and patients. Stay tuned for updates as we navigate these changes together for a healthier tomorrow. This year there are significant changes to EM services and prolonged services that will require a complete change in the way services are coded outside of the office setting as well as new times for determining prolonged services for Medicare patients. Annually CMS publishes its proposed rule for physician practices outlining new policies, codes, coding guidelines, and fee schedules This rule is a must for physician offices to read and be aware of all the changes within the CMS system. Register, https://conferencepanel.com/conference/cms-physician-proposed-rule-2024

1. Jan Rasmussen
PCS, CPC, ACS-OB, ACS-GI
Professional Coding Solutions
CMS Physician
Proposed Rule 2024
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2. • CY 2023 PFS conversion factor is
$33.06
–Decrease of $1.55 to the CY 2022 PFS
conversion factor of $34.61.
–Many E/M services had RVU reductions
from 2022 to 2023 due to category
deletions and combining of categories
2023 Conversion Factor
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3. • Extended 2021 documentation guidelines to determine a
level of E/M service to all additional EM services i.e.,
hospital inpatient, hospital observation, emergency
department, nursing facility, consults, home services/
residence services and cognitive assessment
– CMS accepted new documentation guidelines and E/M
code changes except for prolonged services.
• Deleted several code categories in conjunction with new
combined EM categories.
• Eliminated codes with same decision making levels.
2023 CPT E/M Changes
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4. • Deleted Hospital Observation Services E/M
codes 99217-99220
• Deleted Domiciliary, Rest Home (e.g., Boarding
Home/Assisted Living), or Custodial Care
Services E/M codes 99324-99238, 99334-
99337, 99339, 99340
• Deleted Consultations E/M codes 99241 and
99251
Deleted Codes and Categories
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5. • Hospital Inpatient/Observation Care Category
– Codes 99221-99223 and 99231-99233 now include both
inpatient and observation care
– Same day codes 99234-99236 also now apply to both
inpatient or observation care
• New CMS add on code G0316 for inpatient/observation
prolonged service to be reported in conjunction with 99223,
99233 or 99236
– Do not report G0316 for any time unit less than 15
minutes
– Do not report G0316 on the same date of service as
other prolonged services for evaluation and management
codes 99358, 99359, 99418, 99415, 99416)
Combined Categories
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6. • New Home/Residence Services category 99341-
99342, 99344-99345 (new pt); 99347- 99350
(est.pt)
– Consolidation of Domiciliary, Rest Home (eg,
Boarding Home/Assisted Living) and Custodial
Care Services combined into one category
• Deletion of Home or Residence Services E/M
code 99343 (moderate decision making) home
visit.
– Overlaps with 99244 which also required moderate
decision making
Combined Categories
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7. • New CMS add on code G0317 code for prolonged
nursing facility service to be reported in
conjunction with 99306 or 99310.
– Do not report G0317 for any time unit less than
15 minutes
– Do not report G0317 on the same date of
service as other prolonged services for 99358,
99359, 9941
Prolonged Services Changes…
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8. • Split shared care may be billed by the provider that
furnishes the substantive portion of a hospital or
nursing facility visit.
• CMS requirements for split shared care in 2023
remain the same as 2022.
– Clinicians who furnish split (or shared) visits will continue
to have a choice of history, physical exam, or medical
decision making, or more than half of the
total practitioner time spent to define the substantive
portion
– Initially intended to require time as the determining factor
of “substantive portion” in 2023
Split Shared Care
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9. • Expanded Medicare coverage for certain colorectal
cancer screening tests by reducing the minimum age
payment limitation to 45 years.
• Expanded the regulatory definition of screening
colorectal cancer tests to include a follow-up after a
Medicare covered non-invasive stool-based
colorectal cancer screening test, 82270 (Cologuard)
and 82272 (hemoccult) returns a positive result.
Colorectal Cancer Screening
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10. • Extended duration of time services are temporarily included
on the telehealth services list during the PHE, but are not
included on a Category I, II, or III basis for a period of 151
days following the end of the PHE
– Category 1: Services that are similar to professional consultations,
office visits, and office psychiatry services that are currently on the
Medicare Telehealth Services List.
– Category 2: Services that are not similar to those on the current
Medicare Telehealth Services List.
– Category 3. Services added to the Medicare Telehealth Services
List during the PHE for which there is likely to be clinical benefit
when furnished via telehealth, but not yet sufficient evidence
available to consider the services for permanent addition under the
Category 1 or Category 2 criteria.
• Continued through the end of CY 2023
Telehealth…
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11. • No existing CPT code that specifically describes the work
and potential resources of a clinician who performs
comprehensive, holistic CPM.
– Chronic pain generally defined as persistent or recurring pain lasting
longer than three months
– Often require longer office visit times, longer follow-up coordinating
care with social workers and case managers, mental and behavioral
health support, communications with emergency department
physicians and nurses, and numerous medication adjustments
• Prompt more practitioners to welcome Medicare
beneficiaries with chronic pain
• Expect most services to be billed by primary care providers
Chronic Pain Management
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12. • FDA-approved labeling for a drug packaged in a single-
dose container typically includes statements instructing
users to discard unused portions
• When a provider must discard the amount of drug that
was unused (that is, the discarded amount) from a
single-dose container or other single-use package of a
drug after administering a dose to a Medicare
beneficiary, the program provides payment for the
unused and discarded amount as well as the dose
administered, up to the amount of the drug indicated on
the vial or package labeling.
– JW modifier used to report the amount of a drug that
is discarded and eligible for payment.
Discarded Drugs…
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13. • Now covered in RHC and FQHC chronic
pain management (G3002) and
behavioral health integration services
(G0323) under G0511.
– When CPs and CSWs furnish the services described in HCPCS
code G0323 in an RHC or FQHC, they can bill HCPCS code
G0511.
– May be billed alone or with other payable RHC or FQHC
services
RHC & FQHC
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