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ADVOCACY ALERT: CMS Releases 2024 Medicare Physician Fee Schedule and Hospital Outpatient Prospective Payment System Final Rules

The Centers for Medicare & Medicaid Services (CMS) released the 2024 Medicare Physician Fee Schedule (MPFS) and the Hospital Outpatient Prospective Payment System (HOPPS) final rules. Your advocacy team is analyzing both rules and will report to you on specifics that may impact your practice. The following is ASNC's top-line analysis:

PHYSICIAN FEE SCHEDULE CONVERSION FACTOR

CMS's proposed conversion factor for 2024 is $32.74, a decrease of $1.15 (or 3.37 percent) from the 2023 conversion factor of $33.89. The cut is largely attributed to budget-neutrality requirements triggered by the impending Jan. 1, 2024, implementation of G2211, an office/outpatient evaluation and management visit complexity add-on code.

The only way to stop physician payment cuts next year is for Congress to act. ASNC members are encouraged to take action now


MEDICARE APPROPRIATE USE CRITERIA PROGRAM
 

CMS has finalized its proposal to pause the Appropriate Use Criteria (AUC) Program for advanced diagnostic imaging and to rescind the AUC Program regulations, effectively ending the program's “educational and operational testing period.” In September comments to CMS, ASNC strongly supported CMS's decision to not advance the program by highlighting the flaws with the basic underpinnings of the program as set in statute by Congress.

In the final rule, CMS affirmed a position long-advocated by ASNC that encouraging AUC consultation is inherent in existing Medicare quality programs and that a siloed, standalone AUC program is unnecessary. The final rule says: 

'While a standalone program specifically requiring AUC consultation when ordering advanced diagnostic imaging services would directly target goals of improving advanced diagnostic imaging ordering patterns, our experience in recent years has demonstrated that the goals of appropriate, evidence based, coordinated care can be achieved more effectively, efficiently and comprehensively through other CMS quality initiatives.'

CMS has stated it intends to reevaluate the program but did not say when implementation efforts may recommence.


HOSPITAL OUTPATIENT UPDATE

CMS finalized an inflationary update to HOPPS payment rates by 3.1 percent for hospitals that meet applicable quality reporting requirements. This update is based on the projected hospital market basket increase of 3.3 percent, reduced by a 0.2 percentage point for the productivity adjustment.


PET/CT CODES

In the 2024 HOPPS proposed rule, CMS proposed reassigning Code 78431 Myocardial imaging, positron emission tomography, perfusion study (including ventricular wall motion[s] and/ or ejection fraction[s] when performed) multiple studies at rest and stress (exercise or pharmacologic), with concurrently acquired computed tomography transmission scan – into Ambulatory Payment Classification (APC) 1522 due to a decrease in the geometric mean costs associated with the service.

Following the release of the 2024 proposed rule this summer, ASNC commissioned an analysis of hospital reporting data associated with Code 78431 that duplicates CMS's own analysis. ASNC's analysis showed no anomalies in the hospital reporting data. ASNC is now exploring opportunities to ensure hospitals remain accurate in their reporting going forward. Unfortunately, CMS has finalized the proposed reassignment of Code 78431, and a cut to the reimbursement rate for this service will be implemented in 2024. ASNC will continue working for sustainable reimbursement in both the HOPPS and MPFS systems.

CMS also finalized its proposal to maintain Code 78433Myocardial imaging, positron emission tomography (PET), combined perfusion with metabolic evaluation study (including ventricular wall motion[s] and/or ejection fraction[s], when performed) dual radiotracer – in APC 1521. This results in stable payment for Code 78433 in 2024. 

CMS agreed with ASNC's concern regarding the low volume of claims associated with Code 78432 – Myocardial imaging, positron emission tomography (PET), combined perfusion with metabolic evaluation study (including ventricular wall motion[s] and/or ejection fraction[s], when performed) dual radiotracer (e.g. myocardial viability) – and finalized the use of equitable adjustment authority to prevent a proposed cut. CMS stipulated that it would extend the placement of Code 78432 in APC 1520 for one additional year.


PACKAGING FOR DIAGNOSTIC RADIOPHARMACEUTICALS

CMS is not making changes to its current packaging policy for diagnostic radiopharmaceuticals; however, the agency is considering stakeholder feedback for potential future payment changes. Commenting in response to CMS's solicitation for input, ASNC acknowledged the current packaging policy for diagnostic radiopharmaceuticals in the outpatient setting can create barriers to beneficiary access, particularly in the case of high-cost, low-volume radiopharmaceuticals for certain clinical disease states. ASNC cautioned that before it can confidently make a recommendation on payment changes, it would be imperative to understand the specific impact on nuclear medicine APCs.

In the final rule, CMS acknowledged there was no general consensus among stakeholders who responded to CMS's request for input as to the most effective way for the agency to reform its HOPPS diagnostic radiopharmaceutical payment policy. CMS also noted concern from commenters about how changes could impact nuclear medicine APC rates and the need for full evaluation before any changes could become new policy. 

MORE DETAILS TO C
OME
This summary reflects ASNC's preliminary analysis of both final rules. In the coming weeks, ASNC will provide additional information and will notify you of advocacy efforts, including how you can help. You can participate now by contacting Congress and urging a halt to physician payment cuts. CONTACT CONGRESS

ASNC also will assemble two charts compiling the final reimbursement rates for nuclear cardiology services in 2024. These charts are valuable benefits of ASNC membership in that they provide at-a-glance summaries of the codes that matter most to your practice, helping you make informed budgeting and other practice management decisions. To ensure you continue to receive ASNC's payment charts, alerts on advocacy issues, the Journal of Nuclear Cardiology, and other benefits, RENEW YOUR MEMBERSHIP TODAY

For more information on the 2024 final rules, refer to the following CMS documents: 
Working for you, 
The ASNC Team  

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