2024 Physician Fee Schedule: The Good, the Bad, and the Regulatory
The Calendar Year 2024 Physician Fee Schedule Final Rule is finally here, and with it comes some good news and some bad news (albeit with a small silver lining). Let’s take a look at how each will affect your organization in the new year.
The Bad News: Reimbursement Cut For 2024
CMS has cut reimbursement for therapy providers and physicians once again this year, with the conversion factor down 3.4 percent. But on the bright side, the cut is not as bad as the proposed 4.2 percent decrease. Recently, the APTA, AOTA and ASHA released a set of principles for payment reform. We recommend providers and organizations review and incorporate these principles into their advocacy agendas for 2024.
The Good News: RTM Clarifications, Supervision Updates, and Telehealth News
With the bad news about reimbursement cuts out of the way, let’s dive in and take a look at more positive changes that the Final Rule has for 2024.
Remote Therapeutic Monitoring (RTM) Clarifications & Updates
(MPFS pgs 178-185, 494-503, 570, 763)
CMS continues to support and develop the remote therapeutic monitoring codes, providing several key clarifications that will improve access and flexibility of the service by allowing general supervision of PTAs for enrolled PTs. Other changes include:
- Clarification that RTM codes 98980 and 98981 don’t require 16 days of monitoring.
- RTM is for established patients only.
- Either Remote Patient Monitoring (RPM) or RTM (but not both) can be combined with the following management services: CCM/TCM/BHI, PCM, and CPM (time can’t be double counted).
- Clinicians can provide and bill for RTM during a global surgical period as long as they are not receiving part of the global service payment or if the RTM is being provided for a separate condition from the surgery.
Supervision in Private Practice
The general supervision carve-out for RTM was not the only change made to supervision for therapy providers, as there was a clarification that unenrolled PTs must continue to provide direct supervision for RTM. CMS also finalized an extension to virtual direct supervision until the end of 2024 (Pages 165–171) and continued their discussion of general supervision for private practice overall; however, no changes were finalized on that (pages 494–503).
New Caregiver Training Services (CTS) CPT Codes
CMS finalized three new CPT codes for PTs and OTs — these codes are face-to-face codes to provide caregiver training when the patient is not present. Providers can begin using these codes January 1, 2024.
- 97550 – Caregiver training in strategies and techniques to facilitate the patient’s functional performance in the home or community (e.g., activities of daily living [ADLs], instrumental ADLs [IADLs], transfers, mobility, communication, swallowing, feeding, problem solving, safety practices) (without the patient present), face-to-face; initial 30 minutes
- 97551 – Caregiver training in strategies and techniques to facilitate the patient’s functional performance in the home or community (e.g., activities of daily living [ADLs], instrumental ADLs [IADLs], transfers, mobility, communication, swallowing, feeding, problem solving, safety practices) (without the patient present), face-to-face; each additional 15 minutes.
- 97552 – Group caregiver training in strategies and techniques to facilitate the patient’s functional performance in the home or community (e.g., activities of daily living [ADLs], instrumental ADLs [IADLs], transfers, mobility, communication, swallowing, feeding, problem solving, safety practices) (without the patient present), face-to-face with multiple sets of caregivers.
Telehealth Extension
As proposed, CMS has finalized an extension to telehealth for therapy providers until the end of 2024, but has also finalized its decision not to add the therapy codes to the Medicare Telehealth Services list on a permanent basis. Therapy providers are likely to be disappointed by this decision and will be a major issue to advocate for next year.
For more information, we recommend that providers review the CY 2024 Physician Fee Schedule Final Rule, the Final Rule Fact Sheet and the rule analysis from the APTA.
