CMS finalizes 2024 physician fee schedule: AOA’s 8 takeaways for optometry

Medicare finalizes its annual physician fee schedule update with changes affecting optometry, including adjustments to quality performance measures reporting and a new add-on code necessitating further legislative action on behalf of doctors.

On Nov. 2, the Centers for Medicare & Medicaid Services (CMS) published its calendar year (CY) 2024 Medicare Physician Fee Schedule (PFS) final rule that includes updates and policy changes for payments taking effect on Jan. 1, 2024. Generally, the PFS reflects the administration’s efforts to support primary care, advance health equity, assist family caregivers and expand access to certain modes of health care, while, specifically, setting forth changes to Merit-based Incentive Payment System (MIPS) reporting, billing and coding, and clarifying physician revalidation of enrollment.

The final rule reflects much of the feedback and recommendations shared by the AOA during public comments earlier in the year, yet the AOA continues to review and evaluate the final rule’s effect on optometry. Such is the case; the AOA provides doctors of optometry a brief summary of the 2024 Medicare PFS final rule.

1. Conversion factor reduction.
   CMS finalized a 3.4% reduction in the CY 2024 PFS conversion factor, from $33.88 to $32.74. The AOA continues its advocacy for a fix to the Medicare payment system, and the AOA supports legislation to create a system that maintains a permanent, annual update equal to the increase in the Medicare economic index.
   
   
2. G2211 Add-on Code finalized.
   CMS finalized its new add-on code for primary care, G2211, despite opposition from the AOA and other advocacy groups. This add-on code provides additional payment for certain office visits even though most office visit codes in this category were increased in 2021. Concerns arise that G2211 would inadvertently result in overpayments and consequently result in a reduction in the Medicare conversion factor for all Medicare providers. The AOA has joined a coalition working on a legislative fix to stop implementation of the G2211 code.
   
   
3. MIPS performance threshold increase averted.
   CMS will keep the performance threshold to avoid penalization within MIPS at 75 points. Initially, the CMS proposed increasing this performance threshold to 82 points in 2024, drawing immediate AOA opposition. CMS had estimated increasing the threshold would result in an increase in the number of MIPS-eligible clinicians who would receive a penalty of up to 9%.
   
   
4. Promoting Interoperability category increase finalized.
   CMS finalized its proposal to increase the performance period for the MIPS Promoting Interoperability (PI) category to a minimum of any continuous 180-day period within 2024. This change came despite AOA opposition.
   
   
5. New Quality Measures within optometry/ophthalmology specialty measure set.
   CMS finalized adding new quality measures to the optometry/ophthalmology set, including the following:

Connection to Community Service Provider: Percent of patients, 18 years or older, who screen positive for one or more of the following health-related social needs (HRSNs): food insecurity, housing instability, transportation needs, utility help needs or interpersonal safety; and had contact with a Community Service Provider for at least one of their HRSNs within 60 days after screening.

Appropriate Screening and Plan of Care for Elevated Intraocular Pressure (IOP) following Intravitreal or Periocular Steroid Therapy: Percentage of patients who had an intravitreal or periocular corticosteroid injection (e.g., triamcinolone, preservative-free triamcinolone, dexamethasone, dexamethasone intravitreal implant or fluocinolone intravitreal implant) who, within seven weeks following the date of injection, are screened for elevated IOP with tonometry with documented IOP = 25mm Hg, a plan of care was documented.

Acute Posterior Vitreous Detachment (PVD) Appropriate Examination with Follow-up: Percentage of patients with a diagnosis of acute PVD in either eye who were appropriately evaluated during the initial exam and were reevaluated no later than eight weeks.

Acute Posterior Vitreous Detachment (PVD) and Acute Vitreous Hemorrhage Appropriate Examination and Follow-up: Percentage of patients with a diagnosis of acute PVD and acute vitreous hemorrhage in either eye who were appropriately evaluated during the initial exam and were reevaluated no later than two weeks.

Additionally, CMS also finalized removal of the measure Age-Related Macular Degeneration (AMD): Dilated Macular Examination.

6. Medicare/Medicaid revalidation of enrollment change.
   CMS finalized a policy to allow doctors to receive a stay of enrollment rather than deactivation when they have challenges with revalidation of enrollment. CMS finalized this policy and clarified that doctors will be able to resubmit and be paid for any claims submitted during the stay, after AOA urging.
   
   
7. Delay of mandatory electronic Clinical Quality Measure (eCQM) adoption.
   With AOA support, CMS finalized its proposal to delay mandatory eCQM adoption by Medicare Shared Savings Program (MSSP) participants in 2024.
   
   
8. Public reporting of Cost Measures.
   Lastly, CMS opted against policy changes in CY 2024 that would require public reporting of cost measures. In its proposed rule, CMS proposed publicly reporting procedure utilization data on individual clinical profile pages by incorporating Medicare Advantage data for a more accurate representation of procedure volumes, CMS says. The proposed rule suggested beginning public reporting of cost measures starting with the CY 2024 performance period/2026 MIPS payment year and CMS sought comments for consideration, yet ultimately, CMS chose to continue considering public reporting.

The CMS estimates that optometrists will have total allowed charges of over $1.29 billion in 2024, slightly less than its $1.3 billion estimate for 2023.