CMS releases 2024 MPFS and Hospital OPPS Rules

July 26, 2023

The Centers for Medicare and Medicaid Services (CMS) released its 2024 Hospital Outpatient Prospective Payment System (OPPS) and Medicare Physician Fee Schedule (MPFS) proposed rules.  Based on a preliminary analysis, some of the key provisions for SNMMI are described below.  

OPPS Proposed Rule: 

The most promising news in the OPPS proposed rule is CMS’ requested public comment on “potential modifications to our packaging policy for diagnostic radiopharmaceuticals in order to ensure equitable payment and continued beneficiary access.” They further state that depending on the comments they receive, “we may adopt as final alternative payment mechanisms for radiopharmaceuticals for CY 2024 in the CY 2024 OPPS/ASC final rule with comment period.” Dr Helen Nadel, SNMMI President, stated, “we applaud CMS for requesting comments on this important issue that significantly impacts both patient access and health outcomes.” SNMMI will be evaluating these options and will include detailed recommendations to CMS in our comments.  

CMS proposes updating OPPS payment rates, in accordance with the Medicare statute, by 2.8% for hospitals that meet applicable quality reporting requirements. In addition, CMS proposes new hospital price transparency regulations. These would require each hospital to make its standard charges public and would standardize how hospitals post this information on their websites. 

There is some concerning news regarding payment rates for codes 78431 and 78483, which are cardiac PET-CT perfusion multiple studies and cardiac PET dual radiotracer (i.e., sarcoidosis). Due to hospital cost data, the rates for cardiac PET-CT perfusion multiple studies have gone down 18.2%. The rates for cardiac PET dual radiotracer (i.e., sarcoidosis) has gone down 10.8%.

MPFS Proposed Rule: 

CMS proposed a 2024 physician conversion factor (CF) of $ 32.7476. This represents a 3.36% reduction from the 2023 physician conversion factor of $33.8872. These cuts result from a reduction in the temporary update to the conversion factor under current law and a negative budget neutrality adjustment stemming in part from the adoption of an office visit add-on code. CMS estimates an overall impact of the MPFS proposed changes to nuclear medicine to be a 3% decrease if the proposed changes are finalized. 

CMS will also implement the third year of a phased in clinical labor pricing update, in addition to resuming use of the add-on evaluation and management (E/M) code—G2211—for medical complexity.  

The Agency announced that they will continue to postpone implementation of the updated MEI weights.  A national study to collect representative data on physician practice expenses, the Physician Practice Information Survey, launches on July 31st, 2023.  Data is anticipated to be shared with CMS in early 2025. 

As a result of difficulties with implementation, CMS proposed a “hard pause” on the Appropriate Use Criteria Program for advanced diagnostic imaging services. The Agency will be re-evaluating the program but did not include a timeline. Dr Nadel stated, “we appreciate the difficulties CMS has had with implementation but strongly believe AUCs have been extremely valuable for our members and look forward to continuing to work with CMS on this important program.” 

For MIPS scoring, the category weights for the 2023 performance year are proposed to remain the same as the 2023 weights: Quality – 30%, Cost – 30%, PI – 25%, and IAs – 15%. There are also no proposed quality scoring changes for 2024.  

CMS has provided a Fact Sheet on the MPFS proposed rule, available for review here. 

The 2024 SNMMI charts for both the MPFS and HOPPS proposed rules CY 2024 compared to the current July 2023 rates has also been posted to the website as a resource. 

SNMMI will provide a more detailed analysis in the near future and will submit comments to CMS. 

• MPFS July 2023 Rates Compared to Proposed Rule CY 2024 Rates - Nuclear Medicine Procedures, Radiopharmaceuticals, and Drugs
  
  
• HOPPS CY 2023 FINAL Rates July 2023 Rates 06-29-2023