WASHINGTON July 14, 2023 – Many of the provisions in the proposed 2024 Medicare Physician Fee Schedule (PFS) will help to better recognize the value that internal medicine physicians provide to their patients and have the potential to improve continuity and coordination of care, says the American College of Physicians (ACP). Proposed revisions to the Medicare PFS, Quality Payment Program (QPP), and Medicare Shared Savings Program (MSSP) were released by the Centers for Medicare and Medicaid Services (CMS) Thursday afternoon.
While several proposed updates and changes align with ACP’s recent and longstanding advocacy efforts, we remain concerned about the continued financial instability of the Medicare program and the risk it poses to patient access to care. This continued reduction in payment for physician services jeopardizes access for the nation’s Medicare patients and interferes with physicians’ ability to provide care.
“ACP is committed to working with CMS to address the fragmented payment system and coding and payment deficiencies,” said Omar T. Atiq, president, ACP. “We are disappointed to find the proposed CY24 PFS conversion factor of $32.75 represents a 3.36% across-the-board cut to payment rates as compared to the current CY23 conversion factor of $33.89. While we are pleased with the agency’s proposal to continue to postpone implementation of the updated MEI weights in an effort to balance payment stability, we are concerned about the viability of short-term approaches and continue to partner with a broad coalition to advance structural resolve for a fragmented system.”
But as the agency continues its work to address long-term solutions, the College is strongly encouraged by CMS’ explicit recognition that there exists a potential range of approaches to improve the accuracy of payment for services, especially E/M services. We look forward to providing comments to CMS on ways we can reform the manner in which we establish values for E/M and other services.
Specifically, ACP is pleased that CMS recognizes the inherent complexity for primary care and longitudinal care and strongly supports the proposal to implement G2211 in CY24. The College has long supported implementation of G2211. In response to direct feedback from the College and other stakeholders regarding the impact to the overall budget, the agency is also proposing refinements to its utilization. These refinements include a proposal that this add-on code not be billed with a modifier that, for example, already captures complexity in the valuation. The agency is also proposing to adjust G2211’s utilization estimates, which will reflect positively as inflated estimates result in adverse budget neutrality adjustments for all specialties.
“We are particularly glad to see that CMS included proposals to improve access to behavioral health services, including a proposal to expand the types of practitioners that can furnish behavioral health integration as part of primary care,” continued Dr. Atiq. “Providing coverage and payment for the services of marriage and family therapists and mental health counselors is a significant step in supporting the integration of behavioral services into primary care and better facilitates care provided by internal medicine physicians and their care teams.” The College is also pleased with the agency’s proposal that telehealth services furnished at a patient’s home be paid at the non-facility rate. Improving reimbursement for these arrangements will help protect access to care and aligns with CMS’ previous efforts to recognize the importance of telehealth.”
Additional reactions from ACP include:
- Continuing with its mission of expanding equitable access to care and linking underserved communities with critical social services in the community, CMS is proposing coding and payment for community health integration services. These are the first of their kind and closely align with the principles and recommendations in our 2022 policy paper on Reforming Physician Payments to Achieve Greater Equity and Value in Health Care as well as our 2022 policy paper on Addressing Social Determinants to Improve Patient Care and Promote Health Equity.
- The College is encouraged by several proposals within the MSSP which revise risk adjustment methodology; encourage the participation of clinicians with medically complex, high-cost patient populations; and have significant health equity implications.
- ACP is supportive of the Agency’s proposal to remove the MSSP Certified Electronic Health Record Technology (CEHRT) threshold requirements beginning performance year 2024.
- However, we are discouraged by the proposal to replace that with a new requirement for all MIPS eligible clinicians, Qualifying Participants (QPs), and Partial QPs. The College continues to be concerned by the potential to exacerbate existing administrative burdens.
About the American College of Physicians
The American College of Physicians is the largest medical specialty organization in the United States with members in more than 145 countries worldwide. ACP membership includes 160,000 internal medicine physicians, related subspecialists, and medical students. Internal medicine physicians are specialists who apply scientific knowledge and clinical expertise to the diagnosis, treatment, and compassionate care of adults across the spectrum from health to complex illness. Follow ACP on Twitter, Instagram, and Facebook.