November 6, 2023

CMS released the CY 2024 Medicare Physician Fee Schedule (MPFS) Final Rule on November 2. APMA is currently reviewing the rule and will provide full analysis, as necessary. 

According to the CMS press release, the finalized CY 2024 PFS conversion factor is 32.7442, which reflects a 3.37-percent reduction to the conversion factor relative to 2023. CMS estimates the CY 2024 PFS CF to be 32.7442 which reflects the -2.18-percent budget neutrality adjustment under section 1848(c)(2)(B)(ii)(II) of the Act, the 0.00-percent update adjustment factor specified under section 1848(d)(19) of the Act, and the 1.25-percent payment increase for services furnished in CY 2024, as provided in the CAA, 2023. Some confusion arose because the conversion factor listed in Table 116 of the Final Rule states a CF of 32.7375. We understand that the table is incorrect, and that the preamble language is correct. CMS also provides a fact sheet with a summary of the final provisions. 

APMA is exploring opportunities with its partners in Congress and other medical specialty societies to push for Congressional intervention to prevent the reduction. 

Additionally, the rule finalized several proposals of note: 

• CMS finalized maintaining a Merit-based Incentive Payment System (MIPS) performance threshold of 75 points for 2024, rather than increasing it to 82 points, as proposed. APMA encourages members to prepare for no COVID-related MIPS exceptions for the 2024 performance year. 
• CMS finalized implementation of a separate add-on payment for health-care common procedure coding system (HCPCS) code G2211. This add-on code is designed to recognize the resource costs associated with evaluation and management visits for primary care and longitudinal care. APMA has opposed this addition and is concerned about the negative impact it may have on other code values. 
• CMS is rescinding the Appropriate Use Criteria (AUC) for Advanced Diagnostic Imaging program. APMA has previously educated members about this program which would have required burdensome steps for those ordering MRI, CT scans, or nuclear studies for Medicare Part B outpatients. This decision is a tremendous victory for podiatrists following APMA advocacy in the form of letters and live meetings with CMS representatives during which APMA asked that this program be rescinded. 

For APMA’s previous comments on the proposed rule, visit apma.org/comments and for questions, contact APMA’s Health Policy and Practice Department at healthpolicy.hpp@apma.org.