Provider Groups Oppose Proposed Payment Cuts in Physician Fee Schedule
In addition to opposing the proposed payment cuts, provider groups urged CMS to provide more guidance on E/M coding changes.
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- Provider organizations have made it clear they are not happy with the payment cuts CMS proposed in the 2024 Medicare Physician Fee Schedule (PFS). Additionally, groups have voiced concerns about proposed changes to the Medicare Shared Savings Program (MSSP), coding additions, and threshold increases in the Merit-Based Incentive Payment System (MIPS).
The American Medical Association (AMA), American Hospital Association (AHA), Medical Group Management Association (MGMA), American Medical Group Association (AMGA), and American College of Rheumatology (ACR) penned letters to CMS Administrator Chiquita Brooks-LaSure expressing their thoughts on the proposed PFS.
Payment cuts
Opposition to payment cuts was a common theme in the letters. CMS proposed a 3.34 percent decrease to the conversion factor in 2024, reducing payment rates by 1.25 percent. Some specialties would see reimbursement increases, including internal medicine and family practices, while others would face cuts, including radiation oncology and emergency medicine.
The provider organizations said the proposed payment cuts would exacerbate workforce shortages and impact patient access to care.
“It is evident that these payment cuts are counterproductive to our shared goal of providing high-quality care to Medicare beneficiaries, and simultaneously eroding the financial sustainability of physician practices,” AMA wrote.
AHA’s letter highlighted how the reduction would hurt providers serving historically marginalized communities, especially as they continue to manage ongoing financial pressures stemming from the COVID-19 pandemic.
Similarly, MGMA called the cuts “unsustainable” and urged Congress to provide a positive update to the conversion factor in 2024.
E/M code G2211
CMS proposed implementing a separate add-on payment for the HCPCS code G2211. This would be used with codes for evaluation and management (E/M) visits to recognize the costs clinicians incur when longitudinally treating a patient’s single, serious, or complex chronic condition.
While most provider groups appreciated the reimbursement adjustment that accounts for clinical complexity, they requested more guidance around the change.
“For CMS to properly implement this code, the agency must further refine its utilization assumption, clarify ongoing questions surrounding utilization of the code, and share robust guidance with the provider community,” MGMA wrote.
Additionally, groups are worried about the add-on code’s impact on future conversion factors.
AMGA said it is concerned the add-on code will lead to additional across-the-board cuts, while AHA questioned the redistributive impact of the code.
Promoting interoperability reporting in MSSP
The provider organizations opposed CMS’s proposal to require MSSP accountable care organizations (ACOs) to meet the MIPS Promoting Interoperability (PI) measures. The agency aims to align CEHRT threshold requirements between all ACOs by replacing the MSSP CEHRT threshold requirements with the MIPS PI measures.
“AMGA asserts that the proposed change introduces administrative burden without clear evidence of improved program operations, potentially diverting resources from patient care and coordination,” AMGA’s letter stated. “Ultimately, this approach could undermine the mission of ACOs: fostering high-quality, patient-centered, and cost-efficient care.”
AMA contended that the proposal would counteract the agency’s objective of encouraging more physicians to participate in alternative payment models (APMs).
“The AHA urges CMS not to finalize this policy at this time, and instead focus on advancing policy approaches that can more broadly support wider adoption of EHRs by participants in ACOs,” AHA wrote.
MIPS performance threshold
CMS proposed increasing the MIPS performance threshold from 75 to 82 points for the 2024 period.
“While we understand that the statute requires the QPP to be a budget-neutral program, the burden on care teams to report for MIPS and ongoing frustrations with the program due to the 2022 reporting period increase to 75 performance threshold points are already creating financial stress at a time of extreme uncertainty; rapid increases in performance thresholds may result in unintended consequences, such as further reducing access to care or increasing healthcare disparities, or contributing to practice closures,” ACR wrote.
Similarly, AMA noted that the threshold increase could negatively impact smaller practices and exacerbate health inequities. The letter cited data revealing that around 54 percent of MIPS-eligible clinicians could face penalties averaging 2.4 percent if the 82-point threshold is implemented.
MGMA also urged CMS not to finalize the threshold increase and work to alleviate the burden of MIPS during the 2024 performance period.
