In-Depth Analysis of the 2024 Medicare Physician Fee Schedule Final Rule

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Navigating the 2024 MPFS Final Rule Updates

• Presented By
• Toni Elhoms, CCS, CPC, CPMA, CRC, AHIMA-Approved
  ICD-10-CM / PCS Trainer

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Toni Elhoms, CCS, CPC, CPMA, CRC, AHIMA Approved
ICD-10-CM/PCS Trainer

• CEO Alpha Coding Experts
• Podcast Host Alpha Coding Podcast
• National Speaker - Coding, Compliance, and
  Reimbursement SME
• Former President of Orlando, Florida AAPC
  Chapter
• Expert Witness
• Published Author
• Consultant/Educator/Trainer

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Agenda
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2024 MPFS Updates

• 2024 Final Rule MPFS Conversion Factor (CF) was
  set at 32.7442
• Represented a 1.15/3.37 payment reduction
• 2023 CF was 33.8872
• 2024 Anesthesia CF 20.4349
• Represented a .69 payment reduction
• 2023 CF was 21.1249
• With record-breaking inflation, many industry
  stakeholders were outraged and called for
  Congressional action STAT
• Appropriate Use Criteria Program (AUC) is gone!
• Due to AMA advocacy, CMS maintained the
  performance threshold to avoid a penalty in MIPS
  at 75 points in 2024
• Delayed mandatory eCQM adoption by MSSPs in 2024
• New tool created for ACOs-only called Medicare
  CQMs

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2024 MPFS Updates

• 78 of E-clinicians will avoid a MIPS penalty in
  2026, a significant improvement from the CMS
  projection that 50 of eligible clinicians would
  avoid a penalty in the proposed rule
• CMS will allow CSWs, LMFTs, and MHCs to provide
  health behavior assessment and intervention
  services through CMS
• CMS will allow LPCs, Addiction Counselors, and
  LMFTs to enroll in Medicare and bill as mental
  health professionals greatly expanding access
  to BH Providers
• 400,000 LMFT and MHCs professionals are now able
  to get paid and render services to Medicare
  Beneficiaries

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2024 MPFS Updates

• Medicare Approved List of Telehealth Services
  will continue to be covered through the end of
  2024
• Waived geographic and originating site
  restrictions
• Medicare Approved List of Telehealth Services
  will continue to be reimbursed at non-facility
  reimbursement rates
• Medicare is extending payment for codes approved
  for audio-only Telephone visits based on the
  Medicare Approved List of Telehealth Services
• Medicare will continue to allow direct
  supervision to be provided virtually for the
  Approved List of Telehealth Services

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2024 MPFS Updates

• Split/Shared Visits CMS revised its definition
  of substantive portion of a visit to reflect
  the revisions CPT E/M guidelines state
• Substantive portion more than 50 of the total
  time spent by the physician/QHP performing the
  split/shared visit OR a substantive part of the
  MDM as defined by CPT
• Finally, some alignment between CMS and CPT
• Delayed CMS time-only policy for 3rd year in a
  row

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Remote Patient Monitoring (RPM)
Source Optum360 AMA
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Remote Therapeutic Monitoring (RTM)
Source Optum360 AMA
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Oversight

• Audits
• Internal
• External
• Frequency
• Monthly
• Quarterly

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Resources

• American Medical Association (AMA)
• Centers for Medicare and Medicaid Services (CMS)
• Code of Federal Regulations (CFR)
• CodingIntel.com
• Federal Register
• Foley Lardner LLP
• Optum360

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