The Centers for Medicare & Medicaid Services (CMS) has released the Final Rule for its 2024 Medicare Physician Fee Schedule (PFS).
According to a CMS fact sheet, this update “is one of several Final Rules that reflect a broader administration-wide strategy to create a more equitable health care system that results in better access to care, quality, affordability, and innovation.”
While next year’s payment policies introduce notable changes—some good and others not-so-good— the 2024 Final Rule offers significant opportunities for organizations focusing on care coordination or offering care management programs, particularly for rural health clinics (RHCs) and federally qualified health centers (FQHCs).
Our team has reviewed the 2,700-page Final Rule publication, and has consulted with experts across the industry to provide actionable insights through this article and a webinar.
Here are four key highlights from the 2024 Final Rule.
New remote monitoring coverage for HCPCS code G0511
The existing Healthcare Common Procedure Coding System (HCPCS) code G0511 covers general care management services. However, the CY24 Final Rule will also include Remote Physiologic (or Patient) Monitoring (RPM) and Remote Therapeutic Management (RTM) services starting January 1, 2024.
At that time, G0511 will include coverage across the following service areas:
- Behavioral Health Integration (BHI)
- Chronic Care Management (CCM)
- Remote Patient Monitoring (RPM)
- Remote Therapeutic Monitoring (RTM)
- Community Health Integration (CHI)
- Principal Illness Navigation (PIN)
For the first time, RHCs and FQHCs will be able to use the G0511 code in multiple instances. This means the code can be used to cover 20 minutes of CCM, as well as 20 minutes of RPM. This will enable clinics and centers to create more comprehensive chronic disease management programs.
New coverage for optional screening for social determinants of health during Annual Wellness Visits
Starting in 2024, Medicare will cover a new optional screening for social determinants of health (SDOH) that can be added to an Annual Wellness Visit (AWV).
Under the HCPCS code G0136, the Final Rule stipulates that the SDOH risk assessment does not have to be performed on the same date as the associated E/M or behavioral health visit for the operational ease of practitioners. And, because an AWV may be split over two visits, the SDOH risk assessment could be added as part of the first or second visit, if needed.
Medicare pays 100% of the amount based on the fee schedule for the SDOH risk assessment service without needing beneficiary cost-sharing.
Inclusion and payment for behavioral health MFTs and MHCs
The CMS Behavioral Health Strategy strives to support a person’s emotional and mental well-being through behavioral health care. The Final Rule improves access by allowing marriage and family therapists (MFTs) and mental health counselors (MHCs)—including eligible addiction, alcohol, or drug counselors who meet qualification requirements—to enroll in Medicare and bill for services.
As discussed in section III.B.2.b. of the Final Rule, starting January 1, 2024, RHC and FQHC practitioners can also include licensed MFTs and MHCs as covered providers.
While the CY 2023 Physician Fee Schedule established a new HCPCS code G0323 for care management services related to behavioral health conditions, the 2024 Final Rule refined the work relative value units of both CPT code 99484 and HCPCS code G0323. It will increase from 0.61 to 0.93 and work time from 20 to 21 minutes.
The rule also increases payment for crisis care, substance use disorder treatment, and psychotherapy.
New covered programs
Two new programs, Community Health Integration (CHI) and Principal Illness Navigation (PIN), provide reimbursement for specific support services.
A PIN program identifies Medicare beneficiaries who are diagnosed with high-risk conditions such as dementia, HIV/AIDS, and cancer and connects them with clinical and support resources.
The Final Rule provides additional PIN codes, covering services that are delivered by auxiliary personnel like peer support specialists for conditions such as severe mental illness and substance use disorder.
CHI services will address unmet social needs that affect a beneficiary’s diagnosis and treatment. For CY 2024, the Final Rule clarifies which roles can provide such services through a community-based organization (CBO).
Professionals such as community health workers, care navigators, peer support specialists, and other auxiliary personnel may deliver these services with requisite supervision by a billing practitioner.
These new programs aim to enhance access and reduce health disparities for underserved Medicare populations by engaging a person-centered assessment that can:
- Uncover a patient’s life story
- Provide care coordination
- Contextualize health education
- Build patient self-advocacy skills
- Offer health system navigation
- Facilitate behavioral change
- Provide social and emotional support
- Streamline access to community-based social services to address social needs
Updates to care management conversion factors and payment rates
Overall payment rates under the Physician Fee Schedule will be reduced by 1.25% in CY 2024 compared to CY 2023. The conversion factor—the amount Medicare pays per relative value unit—will see a reduction to $32.75.
That equates to a 3.4% cut of $1.15 from the 2023 rate of $33.89.
In contrast, CMS is finalizing significant increases in payment for primary care and longitudinal patient care. They point to these increases requiring cuts elsewhere to achieve budget neutrality.
ThoroughCare is your technology partner for 2024
ThoroughCare can help you prepare for 2024 with comprehensive tools that simplify care coordination. Our platform was built with Medicare's rules in mind so you and your team can focus on patient care.
Our platform provides the digital infrastructure to leverage fee-for-service programs for value-based success. With seamless EHR integration and data interoperability across health information exchanges and remote devices, our platform supports solutions for:
- Chronic Care Management
- Remote Patient Monitoring
- Behavioral Health Integration
- Annual Wellness Visits
- Transitional Care Management
Providers use ThoroughCare to seamlessly manage populations, capture and act on patient data with interactive care planning and assessments, and visualize business performance to inform decision-makers.
