On July 13, the Centers for Medicare & Medicaid Services (CMS) released the proposed 2024 Medicare Physician Payment Schedule, which impacts Medicare physician payments and the Quality Payment Program (QPP). The California Medical Association (CMA) will be submitting comments by the September 11, 2023, deadline. 

Below are important American Medical Association (AMA) analyses of the fee schedule proposal:   

• A detailed summary of the MFS, which discusses these crucial provisions in depth, as well as many other provisions in the proposal and will provide further understanding of the potential impacts of these changes.
• A specialty impact analysis developed by AMA, which illustrates the combined effect of the budget neutrality proposals in the rule and the reduction to the conversion factor under current law.
• A comprehensive QPP data analysis based on the 2021 performance period, including information about Merit-Based Incentive Payment System (MIPS) scores by specialty and state.

Key highlights of the proposed rule are below:   

• The 2024 Medicare conversion factor (CF) is proposed to be reduced by 3.36% from $33.8872 to $32.7476. The anesthesia conversion factor is proposed to be reduced from $21.1249 to $20.4370. The CF cut is the result of the 1.25% payment cut that Congress allowed to happen in the 2022 year-end legislation and a negative budget neutrality adjustment stemming mostly from the adoption of a new G2211 Evaluation and Management (E&M) office visit add-on code. Overall, the impact by specialty results in a 1-3% increase for primary care and a 0-4% payment cut for specialists, depending on the specialty.
   
• Unfortunately, these cuts coincide with ongoing increases in the cost to practice medicine. CMS projects the increase in the Medicare Economic Index (MEI) practice expense for 2024 will be 4.5%. Physician practices cannot continue to absorb these increasing costs while their payment rates are cut. This is why AMA, CMA, and our partners in organized medicine strongly support H.R. 2474, the Strengthening Medicare for Patients and Providers Act, which would provide a permanent, annual inflation update equal to the increase in the MEI and allow physicians to sustain their practices, make investments in high-value care and maintain patient access to care. Visit AMA’s Fix Medicare Now site and join the fight for financial stability for physician practices and to preserve access to care for Medicare patients. Through the Take Action Now link, CMA is urging you to contact your Member of Congress to urge them to provide an annual inflation update. AMA and CMA are also strongly urging Congress to enact reforms to the Medicare budget neutrality requirements to reduce the severity of cuts.
   
• In a major win for CMA, CMS announced that the agency will postpone implementation of the reweighted MEI practice expenses. The proposal would have reduced the impact of rent and staff wages on Medicare physician reimbursement. Because California is such a high-cost state to operate a medical practice, California physician Medicare payments would have been cut by nearly $100 million. CMA fought the proposal and led a coalition of other high-cost states to urge a delay. CMA joined AMA in urging CMS to wait for the results of the AMA Physician Practice Information Survey (PPIS), which launches on July 31, 2023. CMA believes it will provide more accurate practice expense data to better inform fee schedule payments and urges all California physicians who receive the survey to complete it. Ensuring that California’s higher costs are included in the survey is crucial for California physician stability.
   
• CMA and AMA are strongly opposing the proposal to increase the MIPS performance threshold from 75 points to 82 points, which could result in some physicians receiving a -9% penalty. Research continues to show that MIPS is unduly burdensome; disproportionately harmful to small, rural, and independent practices; exacerbates health inequities; and is not clinically relevant.
   
• Finally, due to AMA advocacy, CMS proposes to delay mandatory electronic clinical quality measure (eCQM) reporting by Medicare Shared Savings Program (MSSP)/accountable care organization (ACO) participants who may continue to use the CMS web interface in 2024.

The text of the proposed rule can be accessed here.

Relevant links: 

• CMS Press Release 
• CMS Fact Sheet on the 2024 Medicare Physician Payment Schedule proposed rule 
• CMS Fact Sheet on 2024 Quality Payment Program proposed changes 
• CMS Fact Sheet on Medicare Shared Savings Program proposed changes