Comment on 2024 Proposed Medicare Payment Policies

ACG, AGA and ASGE submitted recommendations to CMS for improving practice issues and payment rates for gastroenterologists next year. Our comments were in response to CMS’ 2024 proposed rules for the Medicare Physician Fee Schedule, Hospital Outpatient Prospective Payment System and Ambulatory Surgery Centers. We expect CMS to release the final Medicare rules later this fall.

Here are the key points:

  • Prevent the 3.36% cut payments to physicians: CMS overestimated utilization of a new E/M visit complexity code G2211, which will result in cuts to all other codes in 2024. CMS needs to reassess its utilization assumptions for G2211, which could help mitigate cuts to 2024 physician payments.
  • Continue to cover telemedicine: Kudos to CMS for covering audio-only communications until the end of 2024 and for allowing telehealth visits to originate anywhere in the U.S. (including the individual’s home). CMS should continue coverage beyond 2024 with payment rates matching those of office/outpatient E/M visits.
  • Regularly update practice expense (PE) data: Update indirect PE data to reflect today’s costs of running a practice—"current” values are based on 2006 data! We support the AMA’s PE data collection effort. See information below on how you can help.
  • Expand the number of GI tests covered in the ASC setting: To lower costs, add 15 GI diagnostic tests to the list allowed in the ASC setting. These tests can be safely performed in ASCs and moving them out of the hospital setting results in savings.
  • Increase facility payment for POEM: To better align with the procedure’s cost, place CPT code 43497 for Peroral Endoscopic Myotomy (POEM) into a higher-level APC (5331 – Complex GI procedures) with a facility payment of $5,455.74.
  • Finalize the current split/shared visits policy: While CMS fortunately paused its plan to define the “substantive portion” of a visit as simply more than half the total time spent with the patient, the definition is still in flux. We advocate CMS allow facilities to use either one of three key components (history, exam or medical decision making) OR more than half of the total time spent to determine who will bill for the visit. There will not be any changes in 2024.
For more information, see the GI societies’ comment letters: Medicare Physician Fee Schedule (PFS) and Hospital Outpatient Prospective Payment and Ambulatory Surgical Center Payment Systems and our summaries: Medicare Physician Fee Schedule (MPFS) and Medicare Hospital Outpatient Prospective Payment System (OPPS) & Ambulatory Surgical Center (ASC).

Help improve practice expense payments!

Our societies support the AMA’s Physician Practice Information (PPI) survey to better understand costs providers currently face. If you are contacted by Mathematica, the independent research company conducting the survey, please participate.

This is an opportunity for you, as providers, to speak up and support physician payment advocacy. CMS currently uses outdated data from 2006 to develop PE relative values, the Medicare Economic Index and resulting physician payments.

Practices and individual physicians are randomly selected to participate in this study. Participants selected will receive a short patient care survey from their practice or from Mathematica. Be sure to complete the survey if you are selected – this is critical for its success and to ensure that practice expenses and patient care hours are accurately reflected.  


US Multi-Society Task Force Responds to ACP CRC Guidelines

Recently  the US Multi-Society Task Force published a strongly worded comment in Annals of Internal Medicine on the American College of Physicians guidance recommending CRC screening begin at age 50 for average risk individuals.

The task force noted, “we are concerned that [ACP’s] statement may undermine efforts to increase CRC screening in the face of significant increases in the incidence of CRC in those under age 50, and emerging data showing the benefit of screening in this population.”

CRC will be the leading cause of cancer-related death among 20 to 49-year-olds by 2030. Thank you to the MSTF, comprised of the following members, for their unflagging support for our patients.

Swati G. Patel, MD MS; Folasade P. May, MD, PhD, MPhil; Joseph C. Anderson, MD; Carol A. Burke, MD; Jason A. Dominitz, MD, MHS; Seth A. Gross, MD; Brian C. Jacobson, MD, MPH; Aasma Shaukat, MD, MPH; Douglas J. Robertson, MD, MPH.

Read the full comment at the end of the ACP guideline.

About Gastrointestinal Endoscopy
Gastrointestinal endoscopic procedures allow the gastroenterologist to visually inspect the upper gastrointestinal tract (esophagus, stomach and duodenum) and the lower bowel (colon and rectum) through an endoscope, a thin, flexible device with a lighted end and a powerful lens system. Endoscopy has been a major advance in the treatment of gastrointestinal diseases. For example, the use of endoscopes allows the detection of ulcers, cancers, polyps and sites of internal bleeding. Through endoscopy, tissue samples (biopsies) may be obtained, areas of blockage can be opened and active bleeding can be stopped. Polyps in the colon can be removed, which has been shown to prevent colon cancer.

About the American Society for Gastrointestinal Endoscopy
Since its founding in 1941, the American Society for Gastrointestinal Endoscopy (ASGE) has been dedicated to advancing patient care and digestive health by promoting excellence and innovation in gastrointestinal endoscopy. ASGE, with almost 16,000 members worldwide, promotes the highest standards for endoscopic training and practice, fosters endoscopic research, recognizes distinguished contributions to endoscopy, and is the foremost resource for endoscopic education. Visit Asge.org and ValueOfColonoscopy.org for more information and to find a qualified doctor in your area.

 

American Society for Gastrointestinal Endoscopy
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Media Contact

Andrea Lee
Director of Marketing and Communications
630.570.5603
ALee@asge.org