ACP Provides Feedback on Proposed 2024 Medicare Physician Fee Schedule

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In addition to providing support for G2211 and delays to in-person mental health visit requirements, ACP offered guidance for new ways to pay for primary care via alternative payment models

Sept. 22, 2023 (ACP) — The American College of Physicians has sent a 30-page letter to federal officials on the proposed 2024 Medicare Physician Fee Schedule and other federal programs, highlighting areas of strength and recommending changes to other components.

“The Centers for Medicare & Medicaid Services was very responsive to a lot of issues that we care about,” said Shari Erickson, ACP chief advocacy officer and senior vice president. “But the proposed fee schedule is a mixed bag in some areas, and we felt it was important to provide that feedback.”

ACP is dialing up its advocacy efforts as it works with allies to convince Congress to reject plans to cut payment for all physician services by 3.36 percent in 2024.

“Budget-neutral” mandates that force CMS to balance new or higher expenses with cuts elsewhere continue to disrupt the agency's “ability to advance reform and invest in physicians, populations, and services that have long suffered from disinvestment,” ACP writes in the letter. “As evidenced by the past several decades, the current Medicare payment system is a defective approach that cannot be preserved with short-term fixes. While we recognize that we are strongly supportive of other proposals herein included, which impact the adjustment, it is disappointing that worthy revisions and new investments take away from other Medicare priorities.”

On the positive side, ACP strongly supports the proposal to implement the long-delayed G2211 code in 2024. The code allows physicians to be more appropriately reimbursed for complex patient visits. “This code allows physicians to account for the complexity and the time needed for their care,” Erickson said.

While the cost for the code will have to be balanced by cuts elsewhere, “it's important that physicians — including primary care and other internal medicine specialists -- are paid appropriately,” she added.

Erickson said that ACP has been urging CMS to be more realistic about the projected usage of the code. “We're hopeful that CMS will continue to reduce the utilization estimates for this code once they implement it,” she explained.

Meanwhile, ACP is advocating for Congress to allow the code to go forward even as some medical organizations oppose it. “This code is crucial to ensure appropriate payment for the types of services that our members are providing,” Erickson said.

ACP is also urging CMS to reform the American Medical Association/Specialty Society RVS Update Committee, which provides guidance about the value of codes. “We continue to support and engage with the committee, since it allows an opportunity for physician voices to be heard in the code valuation process,” Erickson said. “With that said, we also recognize that it has flaws. It still doesn't really have adequate representation from internal medicine and others involved in primary comprehensive and cognitive-related care.”

The committee should modernize and move beyond a “one-size-fits-all” approach to assigning value to physician services, particularly for evaluation and management services, Erickson explained.

On the telehealth front, ACP also expressed support for plans to delay in-person mental health visit requirements until 2025. “It's really helpful for those who are seeking mental health services in rural or underserved areas,” Erickson said. “They can initiate or continue mental health visits without having to have an in-person visit.”

ACP also offered guidance to CMS about its exploration of new ways to invest in primary care via a hybrid payment model within the Medicare Shared Savings Program. “We provided them with some feedback and pointed to letters that we've put forward with other organizations that lay out principles that they should consider should they implement this model,” Erickson said. “One of them is to be sure that the financial incentives actually get to the primary care physicians rather than just to their organization as a whole.”

ACP submitted its comments in early September. CMS is expected to release the final 2024 payment schedule in late October or early November.

“Once the final rule comes out, we will be reviewing it and sharing with our members so that they know what to expect,” Erickson said. “We will also be updating our Coding resource to reflect these changes.”

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Back to the September 22, 2023 issue of ACP Advocate