ACR Comments on the 2024 Medicare Physician Fee Schedule Proposed Rule

The American College of Radiology® (ACR®) submitted comments to the Centers for Medicare and Medicaid Services (CMS) Sept. 8 that address numerous issues and make specific recommendations related to the 2024 Medicare Physician Fee Schedule (MPFS) proposed rule.

CMS estimates — if the rule is implemented as proposed — a 3% decrease to radiology, while interventional radiology would realize an aggregate 4% decrease, nuclear medicine a 3% decrease, and radiation oncology and radiation therapy centers a 2% decrease. Most of the decrease can be attributed to changes in relative value units (RVUs), the third year of the transition to clinical labor pricing updates and proposed implementation of the Office/Outpatient (O/O) E/M visit complexity add-on code, G2211.

These impacts do not take into account the impact of the congressionally passed 2.50% Consolidated Appropriations Act, 2023 (CAA) payment supplements for 2023 and 1.25% for 2024. As such, the estimated specialty impact mentioned above will be approximately 1% to 2% higher.

The College did not oppose CMS’s proposed pause of the Appropriate Use Criteria (AUC) program for re-evaluation, including pausing the ongoing educational and operations testing period. The College understands the challenges CMS has faced with developing claims processing edits to implement the AUC program in a way that ensures claims are not inappropriately denied when the penalty phase of the program begins. ACR thanked CMS for recognizing the value of AUC consultation and the potential $700,000,000 annual savings to the Medicare program should the program be fully implemented. CMS encourages practices that have already implemented clinical decision support to continue using it. The ACR said it is committed to continuing work with CMS and Congress to ensure the program is successfully implemented.

The CAA moratorium on Medicare payment for O/O E/M visit complexity add-on code, G2211, will end Dec. 31, making it active Jan. 1. The ACR commented that implementation of this add-on code is unnecessary and duplicative of work that can be described by existing codes, and it reduces the conversion factor, which impacts reimbursement for all physicians.

In addition to these topics, the ACR also submitted comments relating to the Quality Payment Program, including the traditional Merit Based Incentive Payment System.

CMS will take into consideration comments received from all stakeholders on the proposed rule and will release its final rule in early November.

For questions about the 2024 MPFS proposed rule and ACR comments, contact Angela Kim, ACR Senior Director, Economics and Health Policy.