The proposed 2024 Medicare Physician Fee Schedule released on July 13 outlined deep cuts to pathologists, independent laboratories, and other specialties to offset increases to other physicians. The CAP has strongly opposed these cuts and is actively lobbying Congress to mitigate the decreases before they take effect.

The Centers for Medicare and Medicaid Services (CMS) published the 2024 proposed Physician Fee Schedule and Quality Payment Program regulation and invited stakeholders to make comments in 60 days. The CAP advocates to protect the value of pathology services and will engage with the CMS to advocate for the profession. Briefly, here are the key topics included in the 2024 proposed rule:

• The CMS proposed to implement evaluation and management add-on code, G2211, causing large budget neutrality adjustments that negatively affect pathologists and other specialties throughout the physician fee schedule. Download the impact table showing the proposed changes to pathology services in 2024.
• The CMS increases Medicare Quality Payment Program (QPP) requirements for 2024.
• Learn more: Register for the CAP’s July 26 webinar providing a comprehensive overview of the proposed fee schedule changes to pathology services and the QPP.

Large Budget Neutrality Adjustments Caused by New Add-On Code

The CMS proposed to implement a new evaluation and management (E/M) add-on code, G2211, for ongoing, longitudinal patient care. This is an add-on code that physicians may list separately in addition to office/outpatient visits for new or established patients (ie, codes 99202-99215). This code may be added even when the E/M visit is done via telehealth because the CMS has permanently added the code to the Medicare telehealth list.

The CMS is not restricting the code’s use to certain specialties but assumes some physicians will utilize the services more than others. In fact, once fully adopted the CMS assumes physicians who rely mainly on office/outpatient E/M visits will report G2211 with 54% of those visits. Primary care specialties will have a higher utilization of the add-on code than other specialties. This increased spending for primary care results in across-the-board cuts to all physician payments. Specialties that do not utilize the new code see larger cuts as a result of its implementation.

The CMS said code G2211 reflects the time, intensity, and practice expense required to build longitudinal relationships with patients and address most of their health care needs with consistency and continuity over long periods of time. In the context of primary care, the CMS believes the code recognizes the resources inherent in holistic, patient-centered care that combines the treatment of illness or injury, the management of acute and chronic health conditions, and the coordination of specialty care in a collaborative relationship with a clinical care team.

The CAP successfully lobbied Congress to delay payment for G2211 in CY 2021 when CMS initially attempted to established payment for the code. The CAP will continue its advocacy efforts to protect the value of pathology services.

Proposed Regulation Impact on Pathology Payment

The 2023 proposed fee schedule indicated the overall impact to pathology payments from 2023 to 2024 would decrease by 2percent. Specifically, the proposed 2024 conversion factor used for the fee schedule’s payment formula is $32.7476, representing a 3.36% decrease from the 2023 conversation factor. This 3.36% decrease to the conversion factor also accounts for the required update to the conversion factor for 2024 of 0%, and the required budget neutrality adjustment to account for changes in relative value units and the implementation of new services. This conversion factor also takes into account a 1.25% increase for 2024 mandated by Congress last year. The CAP continues to aggressively lobby Congress to mitigate these cuts to pathologists for 2024.

AMA and Mathematica Launch New Survey Effort for 2023/2024

The CMS acknowledged the AMA-led Physician Practice Information Survey for 2023-2024 with the primary purpose to collect representative data on practice expense and hours spent in direct patient care. These data will be collected at the specialty level and shared with the CMS to update the Medicare Economic Index and the Resource Based Relative Value Scale. The AMA has contracted the firm Mathematica, an independent research company with extensive experience in survey methods as well as care delivery and finance reform, to conduct this survey. Read more about this initiative.