2024 Medicare Proposed Rule Impacts Patient Access

Posted By: Elizabeth Woodcock Industry,

On July 13th, the Centers for Medicare & Medicaid Services (CMS) issued the calendar year (CY) 2024 Physician Fee Schedule (PFS) proposed rule. The final rule won’t be issued until November, however, the proposal signals how the government is eyeing reimbursement policies for the nation’s largest health insurer – namely, Medicare – for the future.

The ruling has some potential implications about which patient access leaders should be aware; the government is proposing to:

  • Reimburse physicians, advanced practice providers and therapists for caregiver training services, thereby potentially changing how the appointment is scheduled – and with whom (to encourage attendance by and document the caregiver).
  • Recognize and pay community health workers, particularly in underserved communities, as well as peer support and recovery coaches; additionally, marriage and family therapists, mental health counselors, and addiction counselors (that meet applicable requirements) may enroll in Medicare and be paid for their services, thereby necessitating significant changes to the health system’s provider directory and scheduling protocols.
  • Create a new category of payment for Principal Illness Navigation (PIN) services for the treatment of serious, high-risk illnesses including cancer; the proposal incorporates payment for the navigation services often performed within the access center.
  • Add health and well-being coaching services as payable when performed via telemedicine for Medicare beneficiaries, necessitating updates to scheduling decision trees particularly for primary care practices.

The government is also proposing to pay for Social Determinants of Health (SDOH) risk assessments in conjunction with an office visit or the Medicare Annual Wellness Visit (AWV), to include the assessment being added to the telemedicine-covered list; this will add yet another payable screening test for Medicare beneficiaries, a fact that health systems may consider when scheduling patients for preventive visits.

Not surprisingly, CMS announced its intention to implement provisions of the Consolidated Appropriations Act 2023 related to telemedicine. This includes, but is not limited to, coverage and payment of the current Medicare telehealth services list through the end of 2024. Further, the telemedicine payment rate is proposed to continue to be the non-facility (higher) rate for professional services.

For academic health systems, CMS is proposing to allow an exception to the in-person teaching physician requirements for all residency training sites. The government is seeking comments as to their proposal that attending physicians can be present for the key portion of the service through audiovisual, real-time communications technology.

Although the final ruling is yet to be issued, health systems may continue to offer telemedicine services to Medicare beneficiaries without financial penalty. Some have used this fact to convert patients who would have otherwise cancelled their appointment to telemedicine encounters (as clinically appropriate), a switch in appointment type that may be made during the appointment confirmation process when transportation is deemed to be problematic for the patient. Medicare’s pledge to continue payment for telemedicine services furthers these opportunities to engage with patients – and prevent slots from going unused. 

Unfortunately, these gains may be offset by the projected overall reimbursement declines in the ambulatory enterprise. The Medicare payment rate for professional services will be lowered by 3.34%, as proposed. The 2024 conversion factor is set to be $32.75, a decrease of $1.14 from the CY 2023 conversion factor of $33.89. Note that the proposed rate is typically “improved” by Congressional intervention before the final ruling is issued in the fall, but the decline will likely only be softened, not reversed. For provider-based clinics, the news is better – Medicare is proposing a boost in payment for hospital outpatient rates by 2.8%.

For more information, read CMS’ fact sheet on professional services – and the proposed changes to provider-based clinics’ reimbursement. Expect the final rulings to be issued the first week of November 2023. Access leaders should be on the lookout, as changes are clearly in store for 2024.