Introduction to the 2024 Physician Fee Schedule
If you haven’t yet begun accepting telehealth clients for Medicare reimbursement, this year’s update may motivate you to reconsider. The Center for Medicare & Medicaid Services (CMS) is making significant changes to telehealth regulations affecting providers, particularly behavioral health professionals. The proposed changes for CY 2024 include an array of updates like the expansion of Medicare-covered services, revisions in direct supervision norms, and the inclusion of new professional roles. These 2024 Physician Fee Schedule changes are poised to have a multifaceted impact on behavioral health practice, providing opportunities and challenges.
The CY 2024 PFS proposed rule also aims to enhance equity, quality, access, and innovation within the healthcare system. This article outlines key aspects of this proposed rule, including telehealth and community health integration services.
Overview of Physician Fee Schedule (PFS)
The 2024 Physician Fee Schedule (PFS) has been the principal mechanism for Medicare payments for services provided by identified healthcare professionals since 1992. These services can be rendered in many settings, such as offices, hospitals, skilled nursing facilities, and patients’ homes. Payments under the PFS are generally categorized into professional and technical components, each billed separately. The payment rates are determined based on Relative Value Units (RVUs), which consider work, practice, and malpractice expenses and are adjusted geographically (CMS, 2023).
Proposed Changes for CY 2024
Caregiver Training Services
In a novel approach, CMS is introducing proposed payments for caregiver training services for patients with specific diseases or illnesses like dementia. The proposal allows various healthcare providers, including physicians, therapists, and non-physician practitioners like nurse practitioners, to offer these services under an individualized treatment plan. This aligns with the Biden-Harris Administration’s Executive Order to enhance the quality of care by training caregivers.
Addressing Health-Related Social Needs
CMS has proposed changes to address health-related social needs by introducing new codes for Community Health Integration services, Social Determinants of Health (SDOH) Risk Assessment, and Principal Illness Navigation services. These services aim to provide patient-centered care by incorporating multidisciplinary teams that may include community health workers, care navigators, and peer support specialists. This extends the HHS Social Determinants of Health Action Plan and the Biden-Harris Cancer Moonshot initiative.
2024 Physician Fee Schedule Implications for Telehealth and Community Health Services
The proposed rule also has significant implications for telehealth and community health services. For example, caregiver training and Community Health Integration services could be integrated into telehealth platforms, allowing healthcare providers to offer a more comprehensive range of services remotely. This could significantly benefit rural and underserved populations. Furthermore, including community health workers and care navigators aligns well with the existing infrastructure of many telehealth services.
Key Bullet Points for Behavioral Health Professionals
- Temporary and Permanent Additions to Telehealth Services
- Addition of health and well-being coaching services temporarily for CY 2024.
- Social Determinants of Health Risk Assessments will be added permanently.
- Expanded Scope for Telehealth Originating Sites
- Coverage for telehealth services would be possible from any location within the US where the beneficiary resides, including their homes.
- Inclusion of New Telehealth Practitioners
- Expanded definition to include qualified occupational therapists, physical therapists, speech-language pathologists, and audiologists.
- Delay in In-Person Visit Requirements for Mental Health Services
- The requirement for an in-person visit within six months before initiating mental health telehealth services would be delayed. See Telehealth.org’s previous article about the in-person requirement.
- Payment Rates and Billing Codes
- Telehealth services rendered at homes will be paid at the non-facility PFS rate.
- Addition of new HCPCS codes for psychotherapy for crisis services.
- Direct Supervision
- Extension of the definition of direct supervision to allow the presence of the supervising practitioner through real-time audio and video until December 31, 2024.
- Behavioral Health Integration Codes
- Proposing to allow Marriage and Family Therapists (MFTs) and Mental Health Counselors (MHCs) to provide integrated behavioral health care.
- Valuation for Timed Behavioral Health Services
- Proposal to adjust work RVUs for psychotherapy codes under the PFS to better value time-based behavioral health services.
- Opioid Treatment Programs (OTPs)
- Extension of current flexibilities for periodic assessments furnished via audio-only communications through the end of CY 2024.
- General Supervision for Physical and Occupational Therapists
- Proposed regulatory changes to allow for general supervision of therapy assistants by Physical Therapists and Occupational Therapists in Private Practices (PTPPs and OTPPs) for Remote Therapeutic Monitoring (RTM) services.
Please note that these Physician Fe schedule proposals are under review and have yet to be finalized. As such, the information provided should not be construed as definitive regulatory guidelines. Consult the official CMS publication for the most accurate information.
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