Key Areas - 2024 Physician Fee Schedule (PFS) Draft Rule

On July 13, 2023, the Centers for Medicare & Medicaid Services (CMS) released the 2024 proposed rule for Medicare Physician Payment Schedule (MFS) and other changes to Part B Payment and Coverage Policies. If finalized, these policies will take effect on January 1, 2024, unless otherwise noted. Interested parties have a 60-day comment period, which ends on September 11, 2023, to provide feedback and comments on the proposed rule.

Updated Virtual Care (i.e. telehealth) for Idaho Medicaid

In a recent newsletter, the post-pandemic virtual care policy was published and covers most current regulations.  Idaho Medicaid uses virtual care and telehealth interchangeable and defines this as “providing medically necessary health care services without actual physical contact, through the use of electronic means.” Patient and provider need to be interacting in real-time or “live” from two physically different locations, by video or telephone. Idaho Medicaid requires that whomever is providing virtual care must be within provider’s scope of practice and billed as per Medicaid regulations and accurate NPI. 

Drug Management and Key Information Driving Medical Decision Making

Over the years, the AMA and payors have continued to clarify and refine drug management as a part of the medical decision-making risk. In the 2023 guidelines, within the medical complexity tables, column three, there are separate areas addressing prescription drug management (categorized as moderate risk), drug therapy requiring intensive monitoring for toxicity, and parenteral controlled substance (both categorized as high risk). So, what is the difference between these drug managements and when is the intensive drug therapy monitoring supported? Here are some definitions and tips from the AMA and industry research over these risk categories.

CMS 2023 PFS Proposed Rule and Summary of the AMA Revisions for E/M Guidelines

On July 7th, 2022 the Centers for Medicaid and Medicare (CMS) issued the Physician Fee Schedule (PFS) Proposed Rule for 2023. The draft outlines multiple policy changes and 60-day solicitation timeline for public comment. This timeline is crucial for physicians, hospitals, and other stakeholders to provide feedback, case scenarios, and financial impact on draft rules, as this can influence the opinion of the CMS policy makers. We strongly encourage providers and stakeholders to draft responses to issues that impact coding policy and/or reimbursement in the clinic or hospital setting. All the comments are reviewed by CMS and considered.

Telehealth Flexibilities – Post Pandemic

How will telehealth rules change after the pandemic ends? Legislation was in the works early 2021 to create a buffer period after the pandemic official ends and allow providers to make necessary changes prior to the Covid-19 flexibilities. The Consolidated Appropriations Act (the Act) of 2022 was signed into law March 15, 2022 by President Biden extending telehealth flexibilities an additional 151 days after the public health emergency officially ends. The new legislation has several important takeaways that could impact your practice.

AMA Publishes Clarification on 2021 E/M Guidelines

In a March 9th technical correction publication, the AMA clarified several interpretation points of the 2021 Evaluation and Management guidelines. This was anticipated, and likely to continue through this year as providers challenge and question the new counting structure over medical complexity. The clarifications focused on the E/M elements and CPT definitions within the medical decision making table.