The CMS proposed rule for physician payment and coding changes sets the tone for the upcoming year. Attending this update ensures you are well-informed about the latest regulatory changes affecting healthcare services. Understanding the modifications proposed by CMS allows providers to adapt their coding practices, ensuring accurate reimbursement for the services they provide. Knowledge of issues that were not implemented for 2023 provides valuable insights into what CMS is considering for the following year. This foresight enables strategic planning for 2024, allowing healthcare professionals to anticipate and prepare for potential changes. This year's update promises significant changes to key areas such as EM services, splits/shared care, remote patient monitoring (RPM), and complex chronic care management (CCM). Register, https://conferencepanel.com/conference/cms-physician-final-rules-for-2024-find-out-what-cms-has-finalized-from-the-proposed-rules

1. Jan Rasmussen PCS, CPC, ACS-OB, ACS-GI
Professional Coding Solutions
715.595.4278
janrpcs@aol.com
CMS 2024 Final Rule
Find out What CMS has Finalized from the
Proposed Rules
1

2. • CMS states overall physician payments must be
budget neutral
– CMS can’t improve payment in any area of the fee
schedule without cutting it somewhere else.
– The conversion factor may be reduced to offset CPT
codes with increases and newly introduced codes.
• CMS is proposing significant increases in payment
for primary care and other kinds of direct patient
care.
2024 PFS Rate Setting

3. • CY 2024 PFS conversion factor is
$32.74
–Decrease of $1.15 to the CY 2023 PFS
conversion factor of $33.89.
• Final rule includes implementation of
policies mandated by Congress in the
Consolidated Appropriations Act, 2023.
2024 Conversion Factor
3

4. • Originally introduced in CY 2021 and delayed until
this years final rule.
– Encourage holistic, patient-centered care that involves
collaboration and coordination across specialties and
provides continuity and consistency in patient care.
– Establish meaningful relationships with patients and
address their health care needs with consistency and
continuity.
• Stronger clinician-patient relationships can lead to improved
functional health for patients
• Not limited to any specific specialty but must have
ongoing medical relationship with patient’s care
G2211…

5. • Services billed using the physician’s NPI are paid
at a 100% of the PFS rate
– 15% reduction of PFS rate for services billed by QHP
• CMS requirements for split shared care in 2024
were supposed to be based on total time to
determine the “substantive portion”.
• Significant change under the 2024 final rule.
– Substantive portion now either 50% of the
total practitioner time or substantive portion of
medical decision making.
Split Shared Care…

6. • Increased RVUs for global maternity codes
59400, 59410, 59510, 59515, 59610, 59614,
59618, 59622) to allow for previous increases in
values of office/outpatient E/M services
– Global codes that provide a single payment for almost
12 months of services include a relatively large
number of E/M visits performed along with delivery
services and imaging
Maternity Services

7. • Caregiver: adult person who helps care for someone
who is ill, disabled, or aged.
• Recognize and pay for two existing CPT codes which
are currently considered bundled.
– 96202 Multiple-family group behavior
management/modification training for caregiver(s) of
patients with a mental or physical health diagnosis,
administered by physician or other qualified health care
professional (without the patient present), face-to-face with
multiple sets of parent(s)/guardian(s)/caregiver(s); initial 60
minutes
• Requires full 60 minutes before billing add on service
– 96203…each additional 15 minutes
Caregiver Training (CTS)
7

8. • Three new types services that may be provided
by auxiliary personnel incident to the billing
physician or practitioner’s professional services,
and under the billing practitioner’s supervision,
when reasonable and necessary to diagnose
and treat the patient:
– Social Determinants of Health Risk Assessment
(SDOH)
– Community Health Integration Services
– Principal Illness Navigation
New Auxiliary Services
8

9. • Implemented a new code to separately identify and
value a SDOH risk assessment furnished in
conjunction with an E/M visit.
• G0136, Administration of a standardized, evidence-
based Social Determinants of Health Risk
Assessment, 5-15 minutes, not more often than
every 6 months
– Review of the individual’s SDOH or identified social risk
factors that influence the diagnosis and treatment of
medical conditions
– Work RVU of 0.18
– Permanently added to telehealth list including audio only
SDOH Risk Assessment

10. • Two new G codes describing CHI services performed by
certified or trained auxiliary personnel incident to the
professional services and under the general supervision of
the billing practitioner.
– G0019 Community health integration services performed by
certified or trained auxiliary personnel, including a CHW, under the
direction of a physician or other practitioner; 60 minutes per
calendar month, in the following activities to address social
determinants of health (SDOH) need(s) that are significantly
limiting ability to diagnose or treat problem(s) addressed in an
initiating E/M visit:
• RVU 1.00
– G0022…each additional 30 minutes
• RVU 0.70
Community Health Integration

11. • Services to help people with Medicare who are
diagnosed with high-risk conditions — e.g., cancer,
mental health conditions, substance use disorder
(SUD) etc identify and connect with appropriate
practitioners and providers in a timely manner for
care and support resources
– CMS believes most important when a patient is in the
initial stage of treatment as delay in care could be
detrimental/deadly to the patient
Principle Illness Navigation

12. • G0140 – Principal Illness Navigation – Peer
Support by certified or trained auxiliary personnel
under the direction of a physician or other
practitioner, including a certified peer specialist; 60
minutes per calendar month, in the following
activities:
• RVU 1.00, crosswalked to 99490, non complex
chronic care management (first 20 minutes)
• G0146…additional 30 minutes per calendar month
• RVU 0.70 crosswalked to 99439 (additional 20
minutes) non complex CCM
PIN-PS

13. • Implemented several telehealth-related provisions of
the Consolidated Appropriations Act, 2023 (CAA,
2023),
– Temporary expansion of the scope of telehealth
originating sites for services furnished via telehealth to
include any site in the US where beneficiary is located at
the time of the telehealth service, including an individual’s
home
• Finalizing refinements to process to analyze
requests received for the addition of services to the
Medicare Telehealth Services List
– Including determination on whether the requested
services should be added permanently or provisionally.
Telehealth

14. • Implemented provisions from the Consolidated Appropriations
Act, 2023 (CAA), which provides for Medicare Part B coverage
and payment under the Medicare Physician Fee Schedule for
the services of marriage and family therapists (MFTs) and
mental health counselors (MHCs)
– Allow MFTs and MHCs to enroll in Medicare.
– Allow addiction counselors that meet all the applicable
requirements to be an MHC to enroll in Medicare as MHCs.
– Taxonomy codes:
• 106H00000X Marriage and Family therapists
• 101YM0800X Behavioral Health & Social Services
• 101YA0400X Addiction Counselors
• Also applies to RHC and FQHC services
Behavioral Health Services

15. • Health Behavior Assessment and Intervention
(HBAI) CPT codes 96156, 96158, 96159, 96164,
96165, 96167, and 96168, and any successor
codes, may be billed by clinical social workers,
MFTs, and MHCs, in addition to clinical
psychologists
– Used to identify the psychological, behavioral, emotional,
cognitive, and social factors included in the treatment of
physical health problems.
• Allow for better integration of physical and behavioral health care,
• Behavioral health can significantly impact physical health
illnesses.
Behavioral Health Services…

16. • Additional payment for the administration of a
COVID-19 vaccine in the home.
– Extend in-home additional payment to the
administration of three preventive vaccines included
in the Part B preventive vaccine benefit — the
pneumococcal, influenza, and hepatitis B vaccines
• Payment amount for the in-home administration of all four
vaccines will be identical
• Limit additional payment to one payment per home visit, even
if multiple vaccines are administered during the same home
visit
Preventive Vaccine
Administration
16

17. • Expand coverage of diabetes screening to
include the Hemoglobin A1c (HbA1c) test.
• Expand diabetes screening frequency limitations
• Remove the specific clinical test criteria from the
codified definition of “diabetes” for screening,
MNT and DSMT
Diabetes

18. • Change 2023 finalized rule payment policy for dental services
prior to, or during, head and neck cancer treatments,
whether primary or metastatic.
– Permit payment for certain dental services inextricably
linked to other covered services used to treat cancer —
chemotherapy services, Chimeric Antigen Receptor T-
(CAR-T) Cell therapy, and the use of high-dose bone
modifying agents (antiresorptive therapy).
• Improve the success of cancer-related treatments and increase
access to certain dental care.
– Seeking comment on additional circumstances where
evidence supports dental services being integral to the
clinical success of covered medical services.
Dental & Oral Health Services

19. • Final rule 2023 implemented rules requiring
Manufacturers of Certain Single-dose Container
or Single-use Package Drugs to Provide Refunds
with Respect to Discarded Amounts
– Many drugs and biologicals payable under Medicare
Part B are dosed in a variable manner such that the
entire amount identified on the vial or package is not
administered to the patient
• Often times, these drugs are available only in single-dose
containers designed for use with a single patient as a single
injection or infusion
Discarded Drugs

20. 20
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