Nov. 15, 2023
By David Tully
Vice President, AAFP Government Relations
The Academy this month secured an important victory for family physicians — and is working to safeguard that win.
The 2024 Medicare fee schedule and Quality Payment Program final rule, issued Nov. 2, does as the AAFP had long advocated: fully implements G2211, a Medicare add-on code designed to pay more accurately for the complex, high-value visits that primary care physicians provide as part of a continuous relationship with a patient. As my colleague Meredith Yinger, the AAFP’s senior manager of federal policy, will detail for you in this post, G2211 is an important step toward improving patient access and health outcomes, and a strong message that CMS understands the need for Medicare to bolster longitudinal primary care.
Now it’s up to Congress to modernize Medicare’s outdated physician payment system by ensuring that budget neutrality requirements don’t interfere with this important policy advance. Lawmakers must also enact annual inflationary adjustments and provide relief from untenable reductions in physician payment. More about that in a minute.
The AAFP has published a summary for members highlighting the rule’s impacts. To help me point to a few key takeaways in that document, including more wins, I’m joined by Meredith, who leads the AAFP’s advocacy regarding regulatory engagement on payment.
David: How does the final rule compare with what CMS proposed and the guidance we sent?
Meredith: As we acknowledged when responding to the proposed rule, CMS’ authority to address the ongoing, major problems with Medicare payment is limited. Given that boundary and what remains for Congress to do, this final rule is, overall, quite positive for primary care. Our summary lays out the specifics by comparing what we asked CMS to consider and what the rule enacts.
David: Let’s talk about G2211 and family medicine Medicare payment next year.
Meredith: Family physicians will be able to bill G22211 alongside office/outpatient evaluation and management codes to receive separate payment — a big win. The AAFP will provide more information and education to members in the coming weeks to help ensure they can benefit from this new code.
Because of G2211 and other policy changes, we estimate that the aggregate allowed charges to family medicine will increase by about 2% in 2024. The rule notes an additional increase in allowed charges for those in non-facility settings — also positive for primary care. It’s important to note that the impact on individual physicians will vary based on several factors.
The modest bump is because G2211 will help offset a 3.36% reduction to the conversion factor (the amount Medicare pays per relative value unit) from this year’s factor. This fourth consecutive annual payment cut for physicians is due to the usual statutory suspects: the freeze on Medicare physician payment updates, the budget neutrality mandate and the partial expiration of the most recent conversion factor relief.
David: An increase in allowed charges but also a payment cut?
Meredith: Yes — G2211 means that family physicians will receive an additional payment for many of the office visits they provide, but the lower conversion factor means that payments for every other service are going down.
G2211 is an improvement in the value that Medicare assigns to primary care services. It’s a down payment on greater federal investment in primary care. But any policy improvement made under the MPFS is bound to be undermined by the statutory limitations of the Medicare payment system. That's why we need Congress to act — without jeopardizing G2211.
David: And we see signs of positive activity. Major health care committees are considering legislation right now to provide conversion factor relief and modernize budget neutrality requirements.
Next question: CMS says clinicians cannot bill G2211 alongside modifier 25. What does that mean?
Meredith: Modifier 25 is what a physician claims when performing a procedure or providing some other service (such as the Medicare annual wellness visit) on the same day as an office/outpatient evaluation and management visit. We asked CMS to create an exception for annual wellness visits that would allow clinicians to use both G2211 and modifier 25. This guidance is not reflected in the final rule, but we will continue to make our case.
David: Everyone should read our summary, but what are a couple of other significant wins for us in the final rule?
Meredith: As we strongly advocated, the rule keeps the MIPS performance threshold (the final MIPS score a participant must achieve to avoid a negative payment adjustment) at 75 for the 2024 performance year, a meaningful reduction from the proposed 82.
The rule notably finalizes new coding and payment for social determinants of health screenings, community health integration services and principal illness navigation services, in line with our advocacy, and increases the value of general behavioral health integration services, which we also supported.
And CMS will pay for telehealth services in 2024 with a place of service code 10 (patient’s home) at the higher non-facility rate, which we called for.
The AAFP is intensifying its work to ensure that Congress not only supports G2211’s adoption but also addresses Medicare payment and administrative complexity. Late last month, Academy President Steven Furr, M.D., FAAFP, made this case in person, testifying by invitation before the House Energy and Commerce Health Subcommittee.
“As a family physician who has cared for patients for more than 35 years, I can speak firsthand to how years of increasingly onerous administrative red tape and Medicare’s repeated cuts to physician payment, while already undervaluing primary care, are fueling our primary care workforce shortage,” Furr told legislators.
I encourage you, too, to speak firsthand to Congress. Here’s how.
To more comprehensively address inadequate Medicare payment rates, the AAFP has renewed its call on Congress to modernize Medicare’s outdated physician payment system. Family physicians need annual inflationary adjustments and relief from budget neutrality requirements. Our Speak Out tool puts you in touch with your members of Congress so you can join the fight for real, sustainable fixes for Medicare physician payment. Click here today.
Another way to ensure that policymakers understand the needs of your practice and your patients is to respond to the Physician Practice Information Survey. Completing it will take about two minutes, and the information you provide — about the time you spend on patient care each week — is extremely important.
Run by the AMA, in tandem with the consulting firm Mathematica, and endorsed by more than 170 medical societies and other health care associations, the survey is gathering data on practice costs, a key element of physician payment. It’s been more than 15 years since this information was last collected, making this new effort vital in the AAFP’s push for accurate payment.
Practices chosen to participate will receive an email (from firstname.lastname@example.org) and a priority mail packet from Mathematica with a link to the survey and supporting information.