Thursday, November 2, 2023

Very Brief Blog: CMS Posts OPPS, PFS Annual Rules for CY2024

 CMS posted annual final rules for PFS and OPPS on the evening of November 2, 2023.  As usually, CMS posts "typescript" versions and the paginated Fed Reg versions will follow.

PFS 2024

See also Fed Reg on 11/16/23.  The PFS rule weighs in at an extremely unwiedly 200 mb.  88 FR 78818, 1230pp.

Fact sheet here.  

Physician groups decry that their payments continually lag inflation.

OPPS 2024

See also Fed Reg on 11/22/23. 88 FR 81540, 646 pp.


There wasn't much news in the lab or genomics space.  There are minor conforming updates to PAMA regulations regarding years in which PAMA is in effect, mirroring annual legislative edits to the area of law (inspection copy, 795ff).  There is a discussion of updates to CLIA histo and cytopath regs (p. 1473ff).

CMS finalizes payment policy for G2211, an add-on code to primary care office visits that increases their funding for chronic care management.  It has RVU of .33, about $10.  The code had been blocked by Congress earlier.  (Visit complexity inherent to evaluation and management associated with medical care services that serve as the continuing focal point for all needed health care services and/or with medical care services that are part of ongoing care related to a patient's single, serious condition or a complex condition)

In the PFS, CMS declined a multi-stakeholder requst to open a separate track for software policy debate (inspection copy, 69-70).

Of interest in cardiology/radiology, discussion of FFR fractional flow reserve (inspection copy, 241 ff, new CPT 75580, old CPT 0501T-504T).   Note that Heartflow appears also in the OPPS rule (p329ff).  It gets APC 5724, $1024.

Finally, in the PFS rule, while there are quality measures for diabetics involving A1c, for the first time CMS adds A1c as a screening measure, modifying 42 CFR 41018(c) via authority at SSA 1861(yy)(1)(B).   CMS also simplifies the regulatory definition of "diabetes" at 410.18(a).   Several interactions between different measures or rules are discussed. "The proposed revised definition of diabetes for screening purposes will be shortened to describe diabetes as diabetes mellitus, a condition of abnormal glucose metabolism."   There are also some updates to MNT Medical Nutrition Therapy.

The OPPS rule deals with some new codes, like E1905, virtual reality cognitive therapy device (inspection copy p 160) and pulmonary ventilation software analysis (0807T, 0808T, p. 167).  Codes like 0648T, MRI for composition, "Liver Multiscan" is assigned APC as SaaS (p 222 ff).   See similarly cholangiopancreatography software 0723T (p 235ff.)