The Centers for Medicare and Medicaid Services (CMS) recently released the 2024 Medicare Physician Fee Schedule (MPFS) proposed rule. While the American College of Allergy, Asthma and Immunology’s Advocacy Council continues to review the proposed rule to provide a more detailed analysis, we wanted to make you aware of the following key proposals:
- The Medicare Conversion Factor would be set to $32.7476, which is a decrease of 3.34% (or $1.14) from calendar year (CY) 2023. CMS’s policies in the proposed rule would result in an estimated -1% impact for the allergy/immunology specialty. This figure does not take into account other applicable Medicare payment cuts (e.g., sequestration, which could result in more significant cuts).
- CMS would continue to permit the use of real-time, interactive audio and video telecommunications to satisfy the direct supervision requirement through Dec. 31, 2024. For allergists, this means you can continue to provide remote supervision of allergen extract preparation.
- CMS would implement payment for the office/outpatient evaluation and management visit inherent complexity add-on, HCPCS code G2211, for primary and other similar longitudinal care for serious or complex conditions. Under the proposed rule, this code would not be billed with visits reported using Modifier 25.
- CMS would also implement several telehealth-related provisions of the Consolidated Appropriations Act, 2023.
- The Merit-Based Incentive Payment System (MIPS) performance threshold would increase from 75 points to 82 points. Allergists will receive a positive MIPS payment adjustment only if their final score exceeds the performance threshold. Accordingly, this proposal would make it more difficult for allergists to avoid a MIPS-related penalty.
- The Allergy/Immunology Specialty Measures Set would no longer include the Tobacco Use and Help with Quitting Among Adolescents quality measure. CMS proposes to remove this measure as a quality measure from MIPS because it is purportedly duplicative of measure Q226: Preventive Care and Screening: Tobacco Use: Screening and Cessation Intervention.
- Two quality measures would be added to the Allergy/Immunology Specialty Measures Set:
- Connection to Community Service Provider: This measure reports the percent of patients 18 years or older who screen positive for one or more of the following health-related social needs (HRSNs): food insecurity, housing instability, transportation needs, utility help needs, or interpersonal safety; and had contact with a Community Service Provider for at least one of their HRSNs within 60 days after screening.
- Gains in Patient Activation Measure (PAM) Scores at 12 Months: PAM is a 10 or 13 item questionnaire that assesses the patient’s knowledge, skills and confidence for managing their health and health care.
The Advocacy Council will provide additional insights on the proposed 2024 MPFS rule in future Insider articles, and we intend to submit comments advocating for policies that benefit our members.
The Advocacy Council – ADVOCATING FOR ALLERGISTS AND THEIR PATIENTS.
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