capitol hill report: AAN SUBMITS COMMENTS ON 2024 MEDICARE PHYSICIAN FEE SCHEDULE

On September 7, the AAN submitted comments in response to the 2024 Medicare Physician Fee Schedule (PFS) proposed rule. Every year, the Centers for Medicare and Medicaid Services (CMS) issues updates to payment policies and rates for physicians paid under Medicare. In response to the proposals issued by CMS in the PFS, the AAN develops detailed feedback for the agency to consider before changes are finalized and implemented. The proposed rule illustrates the importance of the AAN’s regulatory advocacy efforts on behalf of neurologists and their patients.

CMS is projecting that the overall impact of changes contained in the proposed rule will result in a one-percent increase in payments to neurology as a specialty broadly. Due to the phase-out of temporary relief measures contained in the Consolidated Appropriations Act of 2023 and statutory budget neutrality requirements, CMS is currently predicting a reduction in the Fee Schedule conversion factor of approximately 3.4 percent. The AAN will continue to work with legislators to offset the impacts of statutorily required cuts. The AAN is committed to payment reform efforts to promote a sustainable payment system, such as ensuring physicians receive an inflationary adjustment tied to the Medical Economic Index, and to working with regulators and legislators to ensure that CMS appropriately values the work done by neurologists.

The AAN’s comments focus on high-priority issue areas for neurologists including changes made impacting evaluation and management services, such as the proposed implementation of an add-on code to better account for the work associated with caring for complex patients and a proposed delay in implementation of changes impacting split (or shared) billing that will have detrimental impacts on team-based care. The AAN also provided feedback on changes to existing telehealth policies, such as the extension of critical regulatory flexibilities including continued coverage of audio-only services and waiving site restrictions through 2024, proposed modifications to the list of services on the Medicare Telehealth list, and continued flexibility relating to direct supervision of both staff and residents. In a significant win for AAN advocacy, the AAN is also highly encouraged that CMS is proposing to retire the appropriate use criteria program and rescind all implementing regulations. The AAN also provided the agency with robust feedback on the future of the Quality Payment Program and the need to ensure that reporting requirements are not overly burdensome.