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Physician Fee Schedule

On July 13, 2023, the Centers for Medicare & Medicaid Services (CMS) issued a proposed rule that announces and solicits public comments on proposed policy changes for Medicare payments under the Calendar Year (CY) 2024 Physician Fee Schedule (PFS) and other Medicare Part B issues, effective on or after January 1, 2024.

The calendar year (CY) 2024 PFS proposed rule is one of several proposed rules that reflect a broader Administration-wide strategy to create a more equitable health care system that results in better access to care, quality, affordability, and innovation.

The proposed modifications include several pertaining to telehealth policy in the Medicare program for 2024. One of the major takeaways from the proposed 2024 PFS is the clarification that certain telehealth flexibilities that were previously extended until 151 days after the end of the public health emergency (PHE) have now been extended until December 31, 2024, in accordance with amendments made by the Consolidated Appropriations Act, 2023. These extensions have been known since the CAA’s passage in December last year and has also been addressed in a series of fact sheets and FAQ documents.

However, there were also some new changes addressed in the 2024 PFS. For example, every year CMS will consider adding new services to their list of codes that are reimbursable via telehealth. While they did not decide to add any new codes on a permanent basis to the list (though many remain on the list temporarily through the end of 2024), they did propose to add a number of codes to Category 3 (CMS’ current temporary list), including certain codes for health and well-being coaching services. Additionally, CMS announced a proposed revision to their telehealth code classification process, moving from a Category 1, 2 and 3 classification system to a binary ‘permanent’ or ‘provisional’ classification in an attempt to simplify the process beginning in CY 2025. In order to make the steps for getting a code accepted for inclusion in either the permanent or provisional telehealth lists transparent, CMS proposes a five-step process that is detailed in the proposed 2024 PFS, which includes consideration of the evidence of clinical benefits.

A few additional changes proposed in the document are listed below:

  • The list of telehealth practitioners is amended to recognize marriage and family therapists and mental health counselors as telehealth practitioners, effective Jan. 1, 2024.
  • CMS will pay for place of service (POS) 10 at the non-facility PFS rate, while 02 will be paid at the facility rate beginning Jan. 1, 2024.
  • Frequency limitation would be removed for subsequent inpatient visits through the duration of CY 2024.
  • Multiple clarifications are provided for billing both remote physiologic monitoring (RPM) and remote therapy monitoring (RTM) codes.
  • Direct supervision is allowed to include real-time audio video interactive telecommunication through Dec. 31, 2024 (including for FQHCs and RHCs). Direct supervision requirements are also addressed for occupational therapists in private practice (OTPP) and physical therapists in private practice (PTPP) for unenrolled physical and occupational therapists when providing remote RTM.

CMS will be accepting comments on their proposals until 5:00 pm EST on September 11, 2023, and RCPA will review the document and work with the National Council for Mental Wellbeing in drafting recommendations. We welcome provider feedback and comments to be included and ask that you contact and share these with your RCPA Policy Director.

This week, the Centers for Medicare & Medicaid Services (CMS) announced the Calendar Year 2023 Physician Fee Schedule (PFS) final rule. The final rule includes several National Council and RCPA recommended priorities. These are wins for mental health and substance use care organizations that will help expand access to care by strengthening the workforce.

RCPA recommends members review this 2023 Physicians Fee Schedule Final Rule Summary for impacts on your agencies practice and/or policies.

Key Highlights:

  • Telehealth Flexibility Extensions: CMS is extending telehealth flexibilities implemented under the Public Health Emergency (PHE) for a 151-day period after the expiration of the PHE.
  • CMS is allowing behavioral health clinicians to offer services incident to a Medicare practitioner under general (rather than direct) supervision.
  • Licensed professional counselors and marriage and family therapists are now able to bill incident to Medicare practitioner for their services.
  • Medicare will allow opioid treatment programs to use telehealth to initiate treatment with buprenorphine for patients with opioid use disorder, continuing the flexibilities under the Ryan Haight Act of 2008.
  • CMS is also clarifying that opioid treatment programs can bill for opioid use disorder treatment services provided through mobile units, such as vans, in accordance with Substance Abuse and Mental Health Services Administration (SAMHSA) and Drug Enforcement Administration (DEA) guidance.

The Final Rule, in alignment with the Consolidated Appropriations Act (CAA) of 2022, implements an extension of a number of flexibilities for a 151-day period after the expiration of the Public Health Emergency (PHE), which is set to expire on January 11, 2023.

In the event of further extensions of the federal PHE, we will communicate this info to members. Under the current timeframe for PHE continuation, states must be notified by November 11, 2022.

We thank our members and Steering Committees for their guidance, recommendations, and support through the review process. If you have any questions, please contact your respective RCPA Policy Director.

The Centers for Medicare and Medicaid Services (CMS) has announced that they will hold a call on December 10, 2020 from 1:30 pm – 3:00 pm Eastern Time (ET) that will focus on the calendar year (CY) 2021 Medicare Physician Fee Schedule (MPFS) final rule that was recently released. This call will focus specifically on four key areas within this final rule, including:

  • Extending telehealth and licensing flexibilities beyond the public health emergency (PHE);
  • Updating Evaluation and Management (E/M) coding guidance;
  • Updating the Quality Payment Program and Merit-Based Incentive Payment System Value Pathways; and
  • Updating opioid use disorder and substance use disorder provisions.

During the call, CMS experts will briefly cover provisions from the final rule and address any questions. Members are encouraged to review the final rule prior to the call. To participate, please register here.