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Association Comments on CY 2024 PFS Rule

In a Sept. 11 letter to the Centers for Medicare & Medicaid Services (CMS), America’s Essential Hospitals responded to CMS’ calendar year (CY) 2024 physician fee schedule proposed rule.

In the rule, CMS introduced various policy changes, including a revised conversion factor for physician payment rates, expanded telehealth services with an emphasis on including more locations and practitioners, and a suspension of the appropriate use criteria (AUC) program for advanced diagnostic imaging. CMS also prioritized social determinants of health (SDOH) with an optional risk assessment during Medicare annual wellness visits and a new Healthcare Common Procedure Coding System code for SDOH data collection. Behavioral health services will see coverage expansions and plans to increase payments for at-home vaccine administrations.

Quality programs will have five new Merit-Based Incentive Payment System (MIPS) Value Pathways, focusing on areas such as women’s health and infectious diseases. The Medicare Shared Savings Program (MSSP) is undergoing refinements to incorporate more social risk factors, and there is an emphasis on health equity initiatives.

America’s Essential Hospitals recommended CMS:

  • Expand telehealth reimbursement and lift barriers to Medicare reimbursement for telehealth services, including permanently adding various services to the Medicare reimbursable telehealth services list; providing reimbursement for a wider variety of audio-only services; reimbursing practitioners based on where the telehealth service is provided; and removing telehealth restrictions to ensure equitable access to care.
  • Suspend the implementation of AUC for the Advanced Diagnostic Imaging Program to allow providers sufficient time to update systems, train staff, and revise workflows; and reevaluate how best to promote the program’s objectives.
  • Adopt policies aimed at identifying and addressing SDOH, including introducing new coding to better identify and value services that address SDOH, providing comprehensive guidance and financial resources to effectively carry out SDOH initiatives, and ensuring adequate hospital reimbursement for costs associated with providing Medicare telehealth services.
  • Implement policies within the MSSP that encourage stronger participation by essential hospitals, including revising the beneficiary assignment process, excluding beneficiaries without an Area Deprivation Index (ADI) rank from calculations, and implementing a regional risk score growth cap.
  • Promote more robust participation under the MIPS by essential hospitals, including not increasing the performance threshold, allowing health information technology vendors to submit quality reporting data on behalf of clinicians, and not prematurely releasing aggregated Medicare Advantage data.

Contact Senior Director of Policy Erin O’Malley at or 202.585.0127 with questions.



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