Medicare 2024 Physician Fee Schedule Proposed Rule
We are excited to start diving into the latest Medicare 2024 Physician Fee Schedule Proposed Rule updates. Here we cover three items that could have a significant financial impact next year.
Conversion Factor Changes and Payment Rate Impact
One of the most significant aspects of the proposed rule is the Conversion Factor (CF) update. For 2024, the Centers for Medicare and Medicaid Services (CMS) is proposing a decrease of 3.4% to $32.7476 from 2023 rates. A lower CF implies reduced payment rates from Medicare; however, many moving pieces can ultimately play a part in the BIG picture when attempting to assess the impact.
It's essential for healthcare providers to carefully analyze the potential impact of this change on their revenue streams.
MIPS Reporting Options and Performance Threshold Increase
The Medicare Access and CHIP Reauthorization Act (MACRA) established the Merit-based Incentive Payment System (MIPS), which ties reimbursement to the quality and value of care provided. MIPS offers three reporting options: Traditional MIPS, Alternative Payment Model Performance Pathway (APP), and MIPS Value Pathways (MVPs). Each option carries a set of measures that providers must report on to avoid negative payment adjustments. It should be noted that while MVPs are the newest pathway, it is also being expanded in the Proposed Rule, offering 5 new specialty paths!
In the 2024 proposed rule, CMS aims to enhance the quality of care by raising the performance threshold for all three MIPS reporting options. The performance threshold is the minimum number of points providers must earn to avoid a negative payment adjustment. In 2024, the threshold is proposed to increase from 75 to 82 points. This change poses a challenge for healthcare providers as they strive to meet higher standards to maintain or improve their reimbursement rates.
It is crucial to be aware of where your practice stands currently and assess any operational opportunities to improve these scores if you want to stay ahead of the MIPS game.
Revising the Shared Savings Program Standards
There are many changes impacting the Shared Savings Programs and ACOs. To touch the surface, you should review the following items if you are participating in any of the shared savings’ programs:
- Proposing a new collection type of Medicare CQMs for participants in Medicare Shared Savings Programs and a new option to report quality data utilizing Medicare CQMs in 2024.
- Expansion of the Health Equity adjustment to Medicare CQMs for participating ACOs.
- Alignment of the CEHRT requirements for Shared Savings Program ACOs with the MIPS CEHRT requirements.
- Proposal to modify the Health Equity Adjustment Underserved Multiplier which will impact how patients are assigned to ACOs.
- Proposal to Use Historical Data to Establish the 40th Percentile MIPS Quality Performance Category Score2024 performance standard score would be an average of the 40th percentile MIPS Quality scores from 2020 – 2022.
What can you do?
As the healthcare landscape evolves, medical practices must stay ahead of regulatory changes to safeguard their financial stability and maintain the highest level of patient care. The Medicare 2024 Physician Fee Schedule Proposed Rule brings both challenges and opportunities for providers. This newsletter is just scratching the surface! For a more comprehensive look into the impact on your specialty you can research your specialty society’s response to CMS.
Our team at V2V Management Solutions can assist you in conducting a comprehensive financial analysis to understand how these payment rate adjustments and quality metric changes might affect your bottom line. We can help identify operational opportunities and strategies to optimize revenue while maintaining high-quality patient care.
As always, there is a 60-day comment period to provide feedback on the proposed rule, which closes on September 11, 2023. Comments can be submitted at: https://www.regulations.gov/ (in commenting, please refer to file code CMS-1784-P).
We are committed to being your partner in navigating these changes. Don't let regulatory changes hinder your ability to provide exceptional patient care while maintaining a financially stable practice.
Contact us today and let us help you navigate upcoming changes and discuss operational opportunities that may exist within your practice!
State Specific Impacts
Each state’s licensure requirements to furnish telehealth services have either already been tightened or tied to the end of the PHE. It is essential to understand how your state is handling this individually. We’ve provided links below, which review state-specific guidance.
- Washington: https://doh.wa.gov/public-health-healthcare-providers/telehealth/telehealth-washington-state
- California: https://www.mbc.ca.gov/Resources/Medical-Resources/telehealth.aspx
- For a comprehensive listing of requirements by state, visit:https://www.fsmb.org/siteassets/advocacy/pdf/states-waiving-licensure-requirements-for-telehealth-in-response-to-covid-19.pdf
For More Information Follow These Links2024 Medicare Physician Fee Schedule (PFS) Proposed Rule https://public-inspection.federalregister.gov/2023-14624.pdf
Medicare Physician Fee Schedule Proposed Rule Fact Sheet https://www.cms.gov/newsroom/fact-sheets/calendar-year-cy-2024-medicare-physician-fee-schedule-proposed-rule
Medicare Shared Savings Program Proposed Rule Fact Sheet https://www.cms.gov/newsroom/fact-sheets/calendar-year-cy-2024-medicare-physician-fee-schedule-proposed-rule-medicare-shared-savings-program
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Optimize your Revenue Cycle with our Performance Advantage℠
Understanding all the various nuances of an ever changing reimbursement landscape can seem like a daunting task. The above CMS topics are just a drop in the bucket.
As you look to take your medical practice to new heights of success, consider conducting a revenue cycle optimization review as a cornerstone to achieving financial success.Below are a focus areas to consider as part of an ongoing effort to ensure your revenue cycle is performing optimally:
- regular KPI reporting and benchmarking
- claims management (accuracy, timeliness, and routine payer analysis)
- registration accuracy and financial policies
- technology system integrations and workflows
- staff training and communications
- revenue integrity (charge capture and coding accuracy)
- patient engagement
- auditing and continuous improvements
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Disclaimer: V2V Management Solutions is a healthcare consulting firm. We are not licensed attorneys or certified public accountants. This guide is not intended to replace legal or financial advice from your trusted resources. Before acting on any information provided, check with the appropriate legal or financial team. Healthcare is a constantly evolving landscape; be sure to research for the most current information. The provided content consists of key takeaways on information published in the above referenced articles, facts sheets, and our personal/professional experiences in healthcare management.