New payment policy, coding, and reimbursement changes set forth in the calendar year (CY) 2024 Medicare Physician Fee Schedule (MPFS) final rule took effect on January 1. The MPFS, which the Centers for Medicare & Medicaid Services (CMS) updates annually, lists payment rates for Medicare Part B services and introduces or modifies other policies and regulations that affect physician reimbursement and quality measurement.
The ACS submitted comments September 8, 2023, in response to the CY 2024 MPFS proposed rule issued by CMS earlier in the year.1 Some provisions in the final rule,2 released November 2, 2023, incorporate the College’s recommendations. Although the final rule includes important payment and policy decisions that affect all physicians, this article focuses on updates that are particularly relevant to general surgery and its related specialties.
E/M Services
Split (or Shared) Visits
CMS implemented a new split (or shared) evaluation and management (E/M) billing policy for E/M visits provided in part by a physician and in part by a nonphysician practitioner (NPP) in hospitals and other institutional settings. The billing provider for such visits will be the physician or NPP who furnished the “substantive portion” of the visit. To align with revised Current Procedural Terminology (CPT)* guidelines, CMS defined “substantive portion” to mean “more than half of the total time” spent by the physician or NPP performing the split/shared visit or the “substantive part of the medical decision-making” during the split/shared visit. The ACS provides additional details and suggested coding and billing guidance for split/shared visits in its online Practice Management Resource Center.3
Office and Outpatient E/M Visit “Complexity” Add-On Code
CMS established separate payment for add-on code G2211 to account for visit “complexity” associated with certain office/outpatient E/Ms. Congress had previously placed a moratorium on payment for G2211, and while the ACS supported a continuation of this moratorium, CMS finalized 2024 payment for the add-on code nonetheless.
While guidance remains vague for use of this code, it is not expected that most surgeons will be able to frequently bill for G2211. CMS stated that this add-on code should be reported when furnishing office/outpatient E/M visits associated with medical care services that serve as the continuing focal point for all needed healthcare services and/or with medical care services that are part of ongoing care related to a patient’s single, serious condition or a complex condition. CMS noted that application of the add-on code is not based on the characteristics of particular patients (even though the rationale for valuing such a code is based on recognizing the typical complexity of patient needs) but rather the relationship between the patient and the practitioner. The add-on code is also not available for use with an office/outpatient E/M that is billed with modifier 25.
Additional details about updates to E/M and other coding and billing rules effective this year can be found in the Bulletin article "New 2024 CPT Coding Changes Affect General Surgery, Related Specialties."
Telehealth and Telephone Services
As directed by Congress, CMS expanded the scope of originating sites for services furnished via telehealth to include any site where the beneficiary is located at the time of the telehealth service, including an individual’s home, for 2024. CMS also changed its policy for place of service (POS) codes that should be reported for services furnished via telehealth depending on where the patient was located during provision of such services. CMS now requires use of POS 10 (Telehealth Provided in Patient’s Home), which will be paid at the higher nonfacility MPFS rate, and POS 02 (Telehealth Provided Other than in Patient’s Home), which will continue to be paid at the MPFS facility rate.
In addition to ongoing payment for telephone E/M services through 2024, CMS continues to pay for telephone assessment and management services (CPT codes 98966-98968) for 2024.
AUC for Advanced Diagnostic Imaging
CMS indefinitely paused the appropriate use criteria (AUC) program for advanced diagnostic imaging and rescinded AUC program regulations. Prior to this pause, the AUC program was intended to subject certain providers, specifically those whose ordering patterns for certain imaging services were considered to be “outliers,” to prior authorization requirements.
Conversion Factor
Absent Congressional intervention, the 2024 MPFS conversion factor (CF)—which is the amount Medicare pays per relative value unit—is $32.7442, an approximate 3.4% decrease from last year’s CF of $33.8872. The 2024 CF reflects the reduction in assistance provided by the Consolidated Appropriations Act 2023 (CAA)—from 2.5% for 2023 to 1.25% for 2024—and an additional 2.18% cut due to budget neutrality adjustments (see Table).
