Editor’s Note: The 2024 Physician Fee Schedule Final Rule was released in November 2023. Read our 2024 update for physical therapy and rehabilitation practices.
On July 13, 2023, the U.S. Centers for Medicare & Medicaid Services (CMS) issued their proposed rule for the Calendar Year (CY) 2024 Medicare Physician Fee Schedule (PFS). And tackling the entire proposal is a 2,033-page undertaking!
So, what’s the scoop? What seismic shifts are in the pipeline for rehab therapy practices? How will these changes remodel our compliance landscape as we step into 2024 and stride into the future?
We’ve done the reading for you and put a spotlight on the most important changes included in the CMS Proposed Rule 2024.
CY 2024 Medicare Physician Payment Schedule
Time is money–and according to CMS, we can even put an exact dollar amount on it—so let’s start with some highlights:
- The CMS proposed a 3.3% decrease in the conversion factor, from $33.8872 in CY 2023 to $32.7476 in CY 2024. This decrease is less significant than the anticipated 4.2% cut, but nonetheless will put a strain on thin budgets.
- Telehealth continues through 2024. The end of telehealth allowances for physical therapy would be extended until Dec. 31, 2024.
- The AMA committee would re-review 19 potentially misvalued codes, with the potential for increases. Keep your fingers crossed!
- PT and OT Assistants could experience greater flexibility. In another positive outlook, CMS re-evaluating direct supervision of PTAs and OTAs in private practice–with a request for public comment on the subject. Other changes for PTAs and OTAs include an extension of virtual supervision and a general supervision-only requirement for Remote Therapeutic Monitoring (RTM).
- New caregiver training codes. PTs, OTs, and SLPs who provide training to caregivers, this one’s for you! Look out for the adoption of new billing codes.
These points already capture some significant changes–some for the better, some less so. But if we shift our sights to the horizon, we see some major shifts coming to the rehab therapy field.
Yep, it’s time to talk about MIPS.
Promoting Interoperability for Physical and Occupational Therapies
In the CY 2024 proposed rule, occupational therapy and physical therapy providers will no longer receive the benefit of automatic reweighting for reporting Promoting Interoperability Performance Category as part of the Merit-Based Incentive Payment System (MIPS).
Promoting Interoperability Performance Category constitutes 25% of the total MIPS composite score. With many practices struggling to reach MIPS benchmarks, it’s important that we pay close attention to this change and all that it implies.
What are the requirements for Promoting Interoperability reporting?
To meet the requirements of the Promoting Interoperability Category, practices must:
- Use an electronic health record system certified by the Office of National Coordinator (ONC).
- Participate in this category for 180 days.
- Complete a Security Risk Analysis.
- Complete the SAFER Guides Requirements self-assessment.
- Attest to supporting health information exchange and prevention of information blocking.
- Facilitate timely and secure bidirectional transfer of health information with other providers.
Effectively, this requirement promotes the implementation of interoperable technologies to facilitate seamless, secure information exchange between medical systems, providers, and patients. If the Rule passes without change, practices might consider applying for MIPS Hardship Exceptions, but this may not be a reliable option.
Introducing New MIPS Value Pathways (MVPs)
The Quality Payment Program (QPP) is making the transition from individual reporting to MVPs (MIPS Value Pathways). This is the biggest change to the QPP program since its inception in 2017. The 2023 Final Rule included 12 MIPS Value Pathways; for 2024, CMS has proposed five new MVPs.
What is the purpose of MIPS Value Pathways?
MVPs are a voluntary option for meeting MIPS reporting requirements starting in 2023. According to the QPP resource site: “Each MVP includes a subset of measures and activities that are related to a specialty or medical condition to offer more meaningful participation in MIPS.”
Ultimately, these reporting pathways strive to promote care collaboration, continuous care improvement, shared financial risk, and improved value in healthcare delivery.
All great things–but, understandably, providers have questions about how reporting requirements will affect their specialties and settings.
Is MIPS Value Pathways reporting mandatory?
For the 2023 MIPS reporting year, MVP reporting is voluntary. However, CMS indicated that “[they] intend to sunset traditional MIPS through future rulemaking.” With that in mind, practices should anticipate that MVP reporting will be mandatory in the future.
Learn more about CMS’ plans for MVPs in their Reporting Options Overview or by watching the following video.
Want something a bit more in-depth? Watch this recorded webinar on MVP Measures.
How will MIPS Value Pathways reporting affect the rehabilitation therapy field?
CMS is proposing five new MVPs for the 2024 performance year, including “Rehabilitative Support for Musculoskeletal Care.” This pathway will include rehabilitative specialties like physical therapy and occupational therapy.
The Rehabilitative Support for Musculoskeletal Care category will include:
- 10 quality measures specific to this MVP (e.g., Functional Status Change for Patients with Low Back Pain Impairment), as well as three additional general quality measures (e.g., BMI screening and plan, Fall Plan of Care).
- 17 improvement activities.
- Cost measures for Low Back Pain.
Additionally, all MVP categories are subject to the following Foundational Layer Measures:
- Two population health measures.
- Promoting Interoperability requirements. These include measures such as completing a security risk analysis, supporting electronic referral loops by receiving and reconciling health information, participation in a bidirectional health information exchange, or other activities.
Use this QPP resource to learn more about MVP reporting option benefits, or download the Proposed MVP Guide.
Looking Ahead to the CY 2024 Final Rule
You might be wondering: What will change between now and November?
As we look ahead to the Final Rule, we anticipate that CMS is unlikely to change its stance on requiring PTs and OTs to report scores in the Promoting Interoperability Performance Category.
Why? CMS’ overall goal is to transition all Original Medicare Beneficiaries to Alternative Payment Models by 2030.
What are Alternative Payment Models?
Alternative Payment Models (APMs) are bundled payment models where groups of providers share the financial risk and rewards of caring for patients. APMs are designed to improve healthcare quality through health information exchange and care coordination.
Secure and efficient exchange of health information and patient access to health information is at the core of quality healthcare, and a key component of APMs.
How does transitioning toward MIPS Value Pathways support CMS’ goal to implement APMs?
The introduction of MIPS was one step in the direction of standardizing APMs. Now, MVPs are an even bigger step toward that goal, because it means that providers can report MIPS Performance Measures as a group.
In order for CMS to reach this goal, all providers must make the shift toward interoperable, ONC-certified EHRs that are able to securely connect and share data with other systems.
How to Submit a Public Comment on CMS Proposed Rule 2024
The Proposed Rule is just that–proposed. Individuals, organizations, and anonymous participants were able to submit comments on file CMS-1784-P until September 11, 2023.
Tips for submitting effective comments for CMS review:
- Don’t include PHI. This one should be a no-brainer!
- Try to include industry data to support anecdotal evidence.
- Include examples of how the regulation will affect your industry or practice.
- Offer solutions if you oppose a proposed regulatory measure.
- Don’t use a template, customize your response!
View a full commenters’ guide at Regulations.gov.
The Takeaway
As we approach November’s Final Rule, one thing is clear: In 2024 and beyond, success in the rehabilitation therapy field will require all of us to step up to new standards.
At Raintree Systems–provider of therapy and rehab’s only ONC-certified EHR–we design every solution with a commitment to scalable processes, security, clinical efficiency, and industry-leading compliance standards.
Our eyes are firmly set on the future of the field, and we’re not just observers—we’re setting the pace. Learn more about our award-winning platform by scheduling a demo, today.
