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Academy Analysis: Medicare Physician Fee Schedule 2024

The Consolidated Appropriation Act, 2024 was signed into law on March 9, 2024. The new law provides an additional 1.68% increase to the Medicare Physician Fee Schedule conversion factor (CF) for 2024. This update reduces the initial  3.4% physician payment cut that went into effect on Jan. 1. The updated 2024 CF for dates of service March 9 through Dec. 31 is $33.29. Because the CF update is not applied retroactively, the 2024 CF for dates of service Jan. 1 through March 8 remains at $32.74.

2023 vs. 2024 Comparison Tables

2024 Conversion Factor

The 2024 Medicare Physician Fee Schedule conversion factor (CF) is now $33.29 for services dated March 9 through Dec. 31, 2024. While the updated CF is a 1.77% reduction from the 2023 CF of $33.89, this latest 1.68% statutory boost is an improvement from the $32.74 conversion factor initially enacted for Medicare physician services dated Jan. 1 through March 8, 2024. If Congress had not acted to boost the CF, the 2024 CF would have been a 3.37% reduction from 2023 for the entire year.

Changes to the conversion factor affect each specialty differently, and previous estimates from CMS calculated that ophthalmology faced an estimated 2.25% cut   to Medicare payments for  2024. The effect on individual ophthalmologists will be determined by the mix of procedures they perform.

Most of the overall payment cut reflects CMS’ budget neutrality adjustment to account for the new visit complexity add-on code (CPT G2211) and other updates.

The Academy has steadfastly pushed for payment equity for post-operative visits bundled into global surgical codes. We are disappointed that CMS failed once again to use the final rule as an opportunity to address this issue despite receiving ample feedback from the Academy and Surgical Coalition on strategies for improving global surgical package valuation. The Academy will continue advocating for global payment equity.

Visit Complexity Add-On Code HCPCS G2211

CMS has finalized its implementation of HCPCS G2211, an add-on code for complexity inherent to evaluation and management (E/M) visits. Despite advocacy by the Academy, the AMA and surgical specialties, CMS refused to lower the expected utilization estimate for the code. CMS still believes that G2211 will be billed with 38% of all outpatient office E/M visits initially. As a result, the G2211 code accounts for the majority of the reduction to the conversion factor due to budget neutrality rules.

While the Academy and our advocacy partners believed implementation of the visit complexity add-on code was unnecessary due to the improvements made to E/M visit coding guidelines, there are some situations where ophthalmologists may be able to code for the service. Based upon CMS guidance, the Academy has created resources for coding and billing G2211 for our members.

Specific CPT Code Valuations

Strabismus Surgery CPT Codes 67320, 67331, 67332, 67334

CMS will continue the phase-in of reductions to certain strabismus add-on codes that had cuts of more than 20% finalized in the 2022 Medicare fee schedule final rule. This results in the following changes to these facility-only CPT codes for 2024:

  • +67320 (transposition add-on): 5.14 total RVUs or an allowable payment of $171.10, down from the 2023 allowable of $202.65
  • +67331 (prior eye surgery add on): 4.61 total RVUs or an allowable payment of $156.18, down from the 2023 allowable of $192.82
  • +67332 (extraocular muscle scarring add on): 5.99 total RVUs or an allowable payment of $199.39, down from the 2023 allowable of $208.75
  • +67334 (posterior fixation suture technique add on): 4.54 total RVUs or an allowable payment of $153.99, down from the 2023 allowable of $190.11

New Suprachoroidal Injection Code 67516

CPT 67516 will replace CPT 0465T for the billing of Suprachoroidal injection of a pharmacologic agent starting in 2024. As a temporary category III CPT code, 0465T had not been valued by the RUC.

CMS accepted and finalized the RUC-recommended 1.53 WRVUs and all RUC-recommended direct practice expense inputs without refinement. This results in total allowable payments of $119.17 (nonfacility) and $95.54 (facility) for the suprachoroidal injection of a pharmacologic agent 0-day global procedure.

Amniotic Membrane Implantation Code Family 65778, 65779, 65780

CMS accepted and finalized the recommended RUC work values for the Amniotic Membrane Implantation Procedure family, as well as all RUC-recommended direct practice expense inputs.

This change results in total allowable payments of:

  • 65778: $1,086.50(nonfacility) and $43.27 (facility), down from the 2023 allowables of $1,345.66 (nonfacility) and $52.53 (facility)
  • 65779: $1,154.08 (nonfacility) and $116.17 (facility), down from the 2023 allowables of $1,157.93 (nonfacility) and $146.05 (facility)
  • 65780: $586.19 (facility), down from the 2023 allowable of $667.92

CPTs 65778 and 65779 have been valued as 0-day global procedures; 65780 was valued as a 90-day global procedure.

Medicare Economic Index Rebasing and Revising

CMS will continue delaying implementation of the policies from the 2023 final rule that rebase and revise the Medicare Economic Index calculation. The agency agrees that the AMA Physician Practice Expense Survey is the best data source and is waiting for the AMA to provide updated survey results in 2024.

If you or your practice receive a request to complete the AMA’s Physician Practice Expense Survey, it is important to fill it out completely and accurately.  

Telemedicine

In an effort to protect access to telehealth services and align with the Consolidated Appropriations Act of 2023, CMS finalized many policies on telemedicine exactly as proposed. Of note, CMS finalized a policy that allows telehealth services furnished to patients in their homes to be paid at the nonfacility payment rate beginning with the calendar year 2024 fee schedule.

Quality Payment Program and MIPS Changes

In response to intense advocacy from the Academy and physician community, CMS will not raise the performance threshold for the Merit-Based Incentive Payment System (MIPS) Performance Year 2024. To provide stability to the MIPS program while CMS is working to transition providers to the new MIPS Value Pathways (MVPs), the performance threshold continues to be 75 points. The agency is also leaving the category weights unchanged: Cost performance 30%; quality performance 30%; improvement activity 15%; and promoting interoperability 25%.

CMS finalized three new quality measures related to ophthalmology for MIPS reporting in 2024.

  • QID 499: Appropriate Screening and Plan of Care for Elevated Intraocular Pressure Following Intravitreal or Periocular Steroid Therapy
  • QID 500: Acute Posterior Vitreous Detachment Appropriate Examination and Follow Up
  • QID 501: Acute Posterior Vitreous Detachment and Acute Vitreous Hemorrhage Appropriate Examination and Follow-Up

MIPS Value Pathways

CMS also finalized the addition of five new MIPS Value Pathway options to its inventory for the 2024 performance year; however, none are related to ophthalmology. So far there are no ophthalmology-related MVP options.

Through all of these changes, the Academy’s IRIS Registry remains ophthalmologists’ best tool for success in MIPS.

For more information, contact healthpolicy@aao.org.