CY 2024 Medicare Physician Fee Schedule Clears Review at the Office of Management and Budget (OMB)
The OMB review is the final step before the release of the rule. While we have yet to determine the exact date of the rule's release, it will likely be released early this week.
The big question is the final Medicare Physician Conversion Factor (CF) for CY 2024. In the proposed rule, CMS proposed that the 2024 Medicare conversion factor would be reduced by 3.3% from $33.8872 to $32.7476. Similarly, the agency proposes reducing the anesthesia conversion factor from $21.1249 to $20.4370. This reduction results from an estimated increase in spending that is triggering a budget neutrality adjustment and, as a result a reduction to the CY 2024 CF.
Typically, Congress must intervene to address CF reductions.
In 2024, the implementation of code G2211, finalized in 2021 but then delayed for three years by Congress, is driving the reduction in the CY 2024 CF.
G2211 is an add-on code for E/M services that describes increased patient complexity.
CMS estimates that G2211 will be billed with 38% of all office and outpatient E/M visits initially and 54% of visits once fully implemented. This is down from a utilization assumption of 90% when it was first proposed in 2021.
The implementation of this code has been quite controversial. In proposed rule comment letters, the primary care community largely supported the code, and the surgical community opposed its implementation.
If CMS revises its utilization assumptions once again, as requested by some stakeholders, and reduces the utilization assumption, this could mitigate the reduction to the CY 2024 CF in the final rule.
As we wait to hear the agency’s decision, the one thing that probably unites all of us is the hope that CMS does not release the rule on Tuesday and ruin Halloween!! 🎃