CMS released both the 2024 OPPS and 2024 MPFS Proposed Rules.  The lengthy proposals contain a number of notable provisions including:

2024 OPPS Proposals:

• 2.8% payment increase for eligible hospitals
• Establishment of an intensive outpatient program (IOP) for mental and behavioral health services, as well as, substance abuse services
• Modification of certain aspects of the price transparency requirements which will require hospitals to display standard charges using a CMS template format  
• Adoption of new quality measures

2024 MPFS Proposals:

• 3.4% decrease to the conversion factor (CF). The 2024 CF will be $32.75
• Implementation of G2211 (visit complexity add-on)
• An additional delay of the split/shared rule requiring the substantive portion to be determined solely based on time
• An additional implementation delay for Appropriate Use Criteria (AUC)
• Revisions to covered telehealth services, including teaching physician services
• Expansion of behavioral health services

The Proposed Hospital Outpatient Prospective Payment System Rule is here:https://www.federalregister.gov/public-inspection/2023-14768/medicare-program-hospital-outpatient-prospective-payment-and-ambulatory-surgical-center-payment

The Hospital Outpatient Fact Sheet is here: https://www.cms.gov/newsroom/fact-sheets/cy-2024-medicare-hospital-outpatient-prospective-payment-system-and-ambulatory-surgical-center

The Price Transparency Fact Sheet is here: https://www.cms.gov/newsroom/fact-sheets/cy-2024-hospital-outpatient-prospective-payment-system-opps-policy-changes-hospital-price

The Proposed Medicare Physician Fee Schedule Rule is here: https://public-inspection.federalregister.gov/2023-14624.pdf

The Physician Fee Schedule Fact Sheet is here: https://www.cms.gov/newsroom/fact-sheets/calendar-year-cy-2024-medicare-physician-fee-schedule-proposed-rule

We recommend you review the proposals in their entirety and consider necessary process and policy changes as well as education needs in order to comply with the new requirements, if adopted.

We are here to help.  The HBE team is available to assist you with all of your coding, billing and compliance program needs.  We routinely provide compliance partner services to large health systems as well as physician practices. Our services include:

• Risk Assessments
• Coding accuracy review
• Clinical documentation improvement reviews
• Policy and procedure development
• Customized education and training for clinical and administrative staff