Taking a Closer Look at the 2024 Proposed Physician Fee Schedule

Physician Fee Schedule Overview

The calendar year (CY) Physician Fee Schedule (PFS) is the annual regulatory rule released by the Centers for Medicaid and Medicare Services (CMS) – it contains proposed policy changes that will, generally, take place during the next calendar year related to the Medicare program.

In July, CMS released the proposed CY 2024 PFS. It should be understood that, at this point, the CY 2024 PFS is a proposal and may be changed significantly. While the CY 2024 PFS will not be finalized until after a period for public comment has been concluded, the proposed changes provide information on what the following year in health coverage will likely look like.  

Telehealth Changes in the 2024 Proposed PFS

As it has been proposed, telehealth has no sweeping changes in the CY 2024 PFS. However, a number of changes, additions, and clarifications will have an impact on telehealth going forward. As highly anticipated, all of the 2023 CAA’s telehealth-related provisions have been extended through the end of 2024.

See below for a brief overview of some of the telehealth services that may be impacted by the proposed CY 2024 PFS:

Remote Monitoring Services

Several clarifications surrounding Remote Physiologic Monitoring (RPM) and Remote Therapeutic Monitoring (RTM) have been issued. CMS does state that RPM should only be provided to established patients going forward – this doesn’t apply to those patients that received RPM services as new patients during the public health emergency (PHE). Those patients are now considered existing patients. Another restriction suspended during the PHE –patients must have at least 16 days of monitoring during a 30 period – is also back in effect.

Additionally, the proposed 2024 PFS has stated that RPM or RTM services can be billed for Chronic Care Management (CCM), Transitional Care Management (TCM), Behavioral Health Integration (BHI), Principle Care Management (PCM), and Chronic Pain Management (CPM). It also clarified that RPM and RTM cannot be billed together. More information can be found in the proposed CY 2024 PFS.

Practitioner Types  

The proposed CY 2024 PFS currently intends to amend regulations to permanently include Marriage and Family Therapists and Mental Health Counselors as “practitioners” that are on the list of permanently eligible telehealth providers.

Eligible Services

CMS defines which services can be delivered via telehealth and reimbursed on the Telehealth Services List. During the PHE, a number of services were added to the Telehealth Services List on a provisional basis as a reaction to the COVID-19 pandemic. Currently, the discussion of which services will be allowed permanently is ongoing – for a more detailed explanation of the process used to add services to the permanent version of the Telehealth Services List, see the CMS website.

Regardless, the proposed CY 2024 PFS has proposed that a number of services have been allowed to continue on a temporary basis as the discussion of their future use is continued and more evidence of their efficacy is gathered. See the box to the right for more information about the types of services allowed and the associated codes.

The proposed CY 2024 PFS has also suggested a new process for determining which services are reimbursable when provided via telehealth. Rather than assigning the codes into numbered categories, as is the process now, this new process would make codes either permanent, provisional, or rejected. This process is intended to simplify current processes – for more information see the full proposed CY 2024 PFS.

Supervision Rules

The proposed CY 2024 PFS has suggested that relaxations to supervision rules made during the PHE – namely those that allowed “direct supervision” to include supervising practitioners available through telecommunications systems – to be continued through the end of 2024. It should be noted that this supervision cannot happen via audio only.

Originating Site Clarification

CMS proposes that beginning in CY 2024, telehealth services furnished to beneficiaries in their homes be permanently paid at the higher, non-facility PFS rate.

 CMS proposes to modify the Place of Service (POS) modifiers that clinicians use to bill for telehealth services and stagger the payment rate for telehealth services provided to beneficiaries at home versus at other originating sites

More Information

This is not a full list of all proposed changes that may impact telehealth in the proposed CY 2024 PFS. For a full list, see the full proposal. It should also be noted that all of these proposed changes, additions, and clarifications are subject to significant changes – this is a proposal and may be adjusted based on public comment and changes in circumstances.

More questions about the PFS? Check out this video from our partners at the Center for Connected Health Policy:

Or view their deep dive and fact sheet around the proposed CY 2024 PFS.

And don’t forget to submit any comments by 5 PM on September 11, 2023!