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Navigating the 2024 Medicare Updates: Care Management Physician Fee Schedule Changes

The forthcoming changes to the Medicare Physician Fee Schedule in 2024 will have a substantial impact on reimbursement for medical practices. The Centers for Medicare & Medicaid Services (CMS) has disclosed that the conversion factor for payments will undergo a 3.4% reduction. Despite this decrease, reimbursement rates for primary care and other direct patient care services are slated to increase. The revised Physician Fee Schedule (PFS) also introduces incentives for practices to participate in Accountable Care Organizations (ACOs), such as the Medicare Shared Savings Program.
 
There exists the possibility of Congressional intervention before the onset of 2024 to mitigate the severity of this payment reduction. Absent such intervention, practices aiming to prevent revenue loss from Medicare Evaluation and Management (E&M) reimbursements must adapt their 2024 strategy to excel in value-based programs. Programs like ACO MSSP, Alternative Payment Models, and/or MIPS can serve as compensatory measures for the diminished E&M encounter revenue.
 
Value-based care offerings, including Chronic Care Management (CCM), present an opportunity for practices to enhance their quality scores and secure necessary Medicare reimbursements.
 

Payment Rate Changes

In the upcoming year, healthcare providers will contend with diminished overall payment rates from Medicare. CMS determines Medicare payments based on the typical resources expended for rendering a service, encompassing work, practice expense, and malpractice expense. Following these considerations, a conversion factor and geographic adjustments are applied to determine the remuneration for practices.
 
Unless Congress intervenes, the 2024 Physician Fee Schedule conversion factor is set at $32.74, indicating a 3.4% decrease from the 2023 conversion factor of $33.89. Practices catering to a significant number of Medicare patients face the prospect of substantial revenue loss. Thankfully, CMS has introduced “significant increases in payment for primary care and other kinds of direct patient care.”
 
These enhanced reimbursements primarily manifest through the introduction of the new Medicare G code, G2211. This code accounts for ongoing, longitudinal care for a patient’s chronic conditions and can be appended to Evaluation and Management (E&M) visits.
 

G2211 Add-On Code

Code G2211 will be officially implemented by CMS in 2024. This supplementary code acknowledges the resource costs associated with E&M visits for primary care and longitudinal care. Healthcare providers can bill this code when serving as the patient’s primary point of care, fostering an enduring relationship while addressing a serious or complex condition.
 
The American Academy of Family Physicians estimates that G2211 will yield a payment of $16.05 for each billing in 2024. This code can be utilized in conjunction with CPT Codes 99202-99215.
 
The introduction of code G2211 signifies Medicare’s recognition of the importance of building enduring relationships with patients as a crucial aspect of healthcare. This code acknowledges the effort invested by providers in establishing human connections and devising comprehensive, long-term treatment recommendations.
 
By utilizing code G2211, healthcare providers can safeguard or even augment their Medicare reimbursements while concurrently nurturing relationships with their patients.
 

The PFS and Chronic Care Management

Medicare’s steadfast commitment to comprehensive, preventive care is evident in the elucidation of rules for Chronic Care Management (CCM) consent in the Physician Fee Schedule for 2024. The schedule clarifies that practices can secure consent for CCM through various means, such as over the phone or in person, and that direct supervision by a provider is not required for consent.
 
CCM consent, which has always been permissible under general supervision, is now explicitly stated, underscoring Medicare’s anticipation that practices will persist in employing CCM in 2024 and beyond. Chronic Care Management aligns seamlessly with CMS’s current emphasis on preventive, longitudinal care.
 
Non-complex CCM provides patients with two or more chronic conditions with 20 minutes of preventive care every month. This care complements and follows up on the care received during visits with their provider.
 
During CCM calls, patients collaborate with their personal care coordinators to establish care goals aligned with their provider’s recommendations, track progress, and manage their chronic conditions. Care coordinators can also connect patients with resources for their Social Determinants of Health (SDOH) needs, such as food pantries, transportation services, housing agencies, exercise programs, and support groups.
 
The Physician Fee Schedule acknowledges the importance of addressing social determinants such as access to safe housing, nutritious food, transportation to appointments, and emotional support in achieving holistic patient health. Chronic Care Management enables practices to focus on these socioeconomic needs and deliver ongoing care to their patients.
 

Medicare Physician Fee Schedule 2024 and MSSP

The Medicare Shared Savings Program (MSSP) undergoes changes in the 2024 Medicare Physician Fee Schedule, aligning with CMS’s overarching strategy of growth, alignment, and equity. These changes build upon previous final rules, incorporating alterations to beneficiary assignment methodology, the introduction of a new collection type for ACOs, and alignment of CEHRT requirements with MIPS.
 

Changes to MSSP Beneficiary Assignment

Starting in 2024, CMS will modify the beneficiary assignment methodology to better acknowledge the contributions of nurse practitioners, physician assistants, and clinical nurse specialists in delivering primary care. This change is expected to increase assignable beneficiaries by over 760,000, potentially augmenting payments for MSSP participants.
 
Completing Annual Wellness Visits and enrolling patients in a Chronic Care Management program can facilitate accurate beneficiary attribution.
 
Medicare patients are typically attributed to the provider conducting their Annual Wellness Visit, and in the absence of an AWV, attribution may be based on plurality of care. Given that CCM providers can bill for up to 12 CCM visits annually, patients are likely to be attributed to these providers.
 
Annual Wellness Visits, CCM, and other value-based care offerings can therefore contribute significantly to solidifying beneficiary attribution, a pivotal component of MSSP.
 

MSSP Medicare Clinical Quality Measures (CQMs)

ACOs participating in the Alternative Payment Model (APM) Pathway of the Shared Savings Program will have a new collection type for quality measures. CMS will provide the ACO with a quarterly list of beneficiaries eligible for Medicare Clinical Quality Measures (CQMs), aiding in the collection of quality data throughout the performance year.
 
Changes to the evaluation of quality measures under MSSP are designed to promote the use of digital data, safeguard ACOs serving complex populations, and align MIPS and MSSP quality measures more closely.
 
In 2024, quality data can be reported using CMS Web Interface measures, electronic Clinical Quality Measures (eCQMs), or MIPS Clinical Quality Measures collection types. From 2025 onwards, ACOs can report quality data using eCQMs, MIPS CQMs, and/or Medicare CQMs.

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