Provider Groups and Organizations Respond to Proposed Physician Fee Schedule

In response to the Centers for Medicare and Medicaid Services’ (CMS) proposed 2024 Medicare Physician Fee Schedule, health organizations submitted numerous comments addressing the rule. We highlight a select number below. A consistent theme came from provider groups who want CMS to reconsider cutting physician pay and avoid financial repercussions that could force them to scale back care. Groups objected to the agency’s plan to reduce doctor pay 1.25% next year.

Comments from Organizations

“The AMA continues to underscore our concerns regarding ongoing conversion factor reductions, specifically the proposed 3.36 percent reduction in the 2024 Medicare conversion factor (CF) … [w]e are deeply concerned that these proposed cuts will have far-reaching implications for both physicians and the patients they serve,” wrote the American Medical Association.

The AMA continued, “While we appreciate that Congress partially mitigated the 4.5 percent cut to the MFS rates that was supposed to take effect in January 2023 through passage of the Consolidated Appropriations Act (CAA) of 2023, the forthcoming -1.25 percent reduction in 2024 that was included in the CAA, compounded by a two percent reduction that took effect for 2023, amplifies the financial stress on physician practices. We urge both Congress and CMS to collaborate urgently to address this pressing issue and ensure that physician practices can continue to provide exceptional care without the strain of financial adversity.”

The Medical Group Management Association (MGMA) echoed the AMA’s comments. “MGMA is deeply concerned with the estimated reduction to the CY 2024 conversion factor and its potential impact on medical group practices. The cuts stemming from the 3.36% decrease to the CY 2024 conversion factor paired with the current inflationary environment are simply unsustainable. In an MGMA poll conducted in August 2023, 95% of medical practices reported that the projected reduction to 2024 Medicare payment would negatively impact their ability to deliver timely, high-quality care to patients.”

“There is a discrepancy between the cost of running a physician practice and actual payment for physician services. These reductions in payment would have a devastating impact on physicians and other healthcare professionals and jeopardize patients’ access to care,” the Association of American Medical Colleges wrote.

Further, the American College of Radiology and nearly 50 provider groups urged Congress to halt the implementation of Healthcare Common Procedure Coding System (HCPCS) code G2211, a CMS-generated add on, meant to be billed with evaluation and management services. This is not uniformly endorsed by provider groups, however, as others, like the American Academy of family Physicians and American College of Physicians, argue in favor of the code.

Additionally, commenters offered support for CMS’ proposal to extend Medicare coverage of telehealth and virtual care services, first made possible during the COVID-19 pandemic, through the end of next year and advocated making this policy permanent.

“The COVID-19 [public health emergency] has made clear that telehealth is a key feature in providers’ toolboxes and, thus, has a permanent place in the future of care delivery,” the American Hospital Association wrote.

The American College of Rheumatology commented, “The ACR firmly believes a more comprehensive telehealth service will improve and be a permanent fixture in the future of healthcare but should serve as a supplemental method of care delivery and not as a substitute for in-person care. These expanded telehealth services are vital for our patients, and the ACR encourages discussion and policies that allow for appropriate reimbursement rates for these services.”

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