CMS Physician Fee Schedule Final Rule

A Brief Summary of the 2024 Medicare Physician Fee Schedule (MPFS) Final Rule

On November 2, 2023, the Centers for Medicare and Medicaid Services (CMS) released the 2024 Medicare Physician Fee Schedule (MPFS) final rule. The final rule has significant implications for provider organizations engaged in value-based care. The final rule is consistent with the recent trends to encourage organizations to shift to value-based care models. CMS finalized that the CY 2024 PFS conversion factor is $32.74, a decrease of $1.15 (or 3.4%) from the current CY 2023 conversion factor of $33.89, impacting fee-for-service reimbursement. However, there has been many significant positive changes around improvements in quality reporting, benchmarking policies, and encouraging accountable care organizations (ACOs) who serve high-cost beneficiaries, especially focusing on social determinates of health and behavioral health.Below is a summary of these changes that specifically impact ACOs:

1. Assignment methodology changes include expansion of the physician visit to two years- accounting for beneficiaries who receive services from nurse practitioners, physician assistants, or clinical nurse specialists.
2. Significant changes to risk adjustment methodology to mirror Medicare Advantage- ACOs will phase in V28 over the next three years.
3. Significant changes to the former requirement for the all patients, all payer model for quality reporting: CMS will share a list of patients that are eligible for CQM, limiting the reporting to only Medicare beneficiaries.
4. Implementation of an add-on code for complexity (G2211), providing additional reimbursement for complex patients.
5. New codes for community health integration services and social determinants of health (SDOH) risk assessment.

The above list of changes is a summary of the key changes—the final rule has so many more complex concepts. We encourage you to read the summary from CMS, as there may be specific items that have a dramatic impact on your organization.