July 14, 2023

CMS issued the calendar year 2024 Medicare Physician Fee Schedule Proposed Rule and Quality Payment Program Proposed Rule on July 13. APMA is still reviewing this almost-2,000-page document. APMA will complete its review in conjunction with consultants and committee members, and submit comments to CMS on these proposals. The 2024 Final Rule is expected sometime in November. Some of the proposals include:

CMS proposes a CY 2024 conversion factor of $32.7476, down about 3.4 percent from 2023
Despite this change in the conversion factor, which will impact all physicians, podiatric physicians on average should see no additional aggregate decreases across the codes they typically use. While this outcome is better than recent proposals that decreased payment to podiatrists, APMA—along with other medical societies—will seek relief on the cut to the conversion factor, as has been the case in recent years.

This proposal to reduce the conversion factor is a result of a reduction in the temporary update to the conversion factor under current law and a negative budget neutrality adjustment. This decision coincides with ongoing growth in the cost to practice medicine as CMS projects the increase in the Medicare Economic Index (MEI) for 2024 will be 4.5 percent. Physician practices cannot continue to absorb these increasing costs without corresponding increases in payment rates. For these reasons, APMA strongly supports HR 2474, the Strengthening Medicare for Patients and Providers Act, which would provide a permanent, annual update equal to the increase in the MEI.

CMS proposes to rescind the Appropriate Use Criteria (AUC) for Advanced Diagnostic Imaging program
This decision is a tremendous victory for podiatrists following APMA advocacy in the form of letters and live meetings with CMS representatives during which APMA asked that this program be rescinded.

G2211
CMS proposes to implement a separate add-on payment for HCPC code G221, recognizing the inherent costs clinicians may incur when longitudinally treating a patient’s single, serious, or complex chronic condition.

Skin Substitute Services
CMS proposes to not move forward with its previous proposal to bundle payment for the application procedure and skin substitute product in the private office setting. This proposal is a tremendous victory for podiatrists following APMA communications to CMS asking that this proposal not move forward.

MIPS
CMS proposes to raise the MIPS score needed to avoid a penalty in 2024 from 75 to 82. APMA will strongly oppose this proposal.