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Wins include planned implementation of the G2211 code for complex primary care visits; however, the proposed conversion factor will lead to further declines in payment

Aug. 11, 2023 (ACP) — The �ܼ�����ˮ��̳ is pleased by many provisions in the proposed 2024 Medicare Physician Fee Schedule (PFS), which was released in July. ACP is especially encouraged by the planned implementation of the long-sought G2211 code that will allow physicians to be more fairly compensated for complex primary care visits.

However, ACP is continuing to raise the alarm about continued declines in payment for physician services. “We are disappointed to find the proposed CY24 PFS conversion factor of $32.75 represents a 3.36 percent across-the-board cut to payment rates as compared to the current CY23 conversion factor of $33.89,” said Dr. Omar T. Atiq, president of ACP. “While we are pleased with the agency's proposal to continue to postpone implementation of the updated Medicare Economic Index weights in an effort to balance payment stability, we are concerned about the viability of short-term approaches and continue to partner with a broad coalition to advance structural resolve for a fragmented system.”

The decline in physician payments would have been even worse if Congress had not approved an increase of 1.25 percent, said Shari Erickson, ACP chief advocacy officer and senior vice president. “But it is still a negative overall conversion factor, which is not ideal,” she said.

Erickson said ACP is happy that the Centers for Medicare & Medicaid Services (CMS) is prepared to finally implement the G2211 code in 2024. Congress delayed its implementation during the pandemic but is now ready to move forward with it, she said.

Physicians will be able to use the code when they see long-term patients and the complexity of the visits are not fully reflected in the applicable evaluation and management (E/M) code, Erickson explained.

“They can add this code on to that level for a visit to ensure that they're getting accurate payment for the work and the value of care they're providing,” she said. “The code recognizes the inherent complexity of longitudinal care, which is critically important for primary care.”

Some critics in the medical community think the code should be delayed — or not implemented at all -- due to its potential to negatively affect other reimbursements. This is due to a “budget neutrality” requirement that extra costs be balanced by cuts. Still, ACP firmly believes the code is warranted and is urging Congress to let it go forward. “We're not in the midst of a public health emergency anymore, and it's time for this code to be implemented,” Erickson said.

ACP is also pleased that CMS included proposals to improve access to behavioral health services, “including a proposal to expand the types of practitioners that can furnish behavioral health integration as part of primary care,” Atiq said. “Providing coverage and payment for the services of marriage and family therapists and mental health counselors is a significant step in supporting the integration of behavioral services into primary care and better facilitates care provided by internal medicine physicians and their care teams.”

In addition, CMS has proposed that telehealth services furnished at a patient's home be paid at the non-facility rate. “Improving reimbursement for these arrangements will help protect access to care and aligns with CMS’ previous efforts to recognize the importance of telehealth,” Atiq noted.

ACP also supports plans by CMS to add coding and payment for community health integration services. These codes are the first of their kind and closely align with the principles and recommendations in the 2022 ACP policy papers on and

“These changes allow separate reimbursement for community health integration and social drivers of health risk assessment services,” Erickson said. For example, “if an internal medicine physician does a risk assessment of that patient's social drivers of health during an annual wellness visit, there's some additional payment that would be associated with that. That's really positive.”

On other fronts, ACP is encouraged by several proposals within the Medicare Shared Savings Program that revise risk-adjustment methodology and encourage the participation of clinicians with medically complex, high-cost patient populations. ACP believes these proposals will significantly support health equity.

ACP also supports a proposal to remove the Medicare Shared Savings Program Certified Electronic Health Record Technology threshold requirements beginning in performance year 2024. However, ACP is discouraged by plans to replace this mandate with a new requirement for all Merit-based Incentive Payment System-eligible clinicians, Qualifying Participants (QPs), and Partial QPs and is concerned it will exacerbate existing administrative burdens.

CMS also released a request for information within the fee schedule proposed rule on how to more regularly and comprehensively evaluate how the agency pays for E/M and other types of services. “We'll be providing pretty robust comments there,” Erickson said.

CMS will accept comments on the proposed PFS during a 60-day comment period, Erickson noted. “ACP is in the midst of putting together our comments now, and we already sent a grassroots alert to our members to provide feedback to both CMS and members of Congress specific to the G2211 code,” she said.

Typically, CMS will take into account all of the comments that they receive and then release a final rule around the end of October or early November, according to Erickson. Then the fee schedule would go into effect on Jan. 1, 2024.

Back to the August 11, 2023 issue of ACP Advocate