2024 CMS Proposed Rule Summary: MPFS Update for Anesthesia & Chronic Pain 

Medicare Conversion Factor

CMS proposed a decrease in the medical/surgical conversion factor for 2024, which is used to determine pricing for non-time-based services (lines, blocks, etc.). The proposed new rate is $32.7476, which is 3.3% lower than the current rate of $33.8872. The national anesthesia conversion factor is also scheduled to be reduced, from $21.1249 to $20.4370 (- 3.3%). This is subject to change, should Congress intervene by the end of the year. Keep in mind that if any of your managed care contracts are tied to a percentage of Medicare (not advised), your rates for those plans will also drop if the proposed rule becomes final in November.

New Code and Reimbursement Track for Percutaneous SI Joint Arthrodesis (Chronic Pain)

CMS proposed a new code and reimbursement methodology for the above-mentioned service, effective 1/1/24. This procedure involves the use of intraarticular implants, such as bone allografts or synthetic devices, without placement of a transfixation device. The proposed work RVU is 7.86, which is 5.3 times the value of an SI Joint block. This puts the Medicare allowance for this new modality at approximately $440. The new code itself has yet to be defined, although it will most likely be in the “20000 section” of the CPT book, similar to SI Joint block code 27096.

New add-on code G2211 for Outpatient E/M Services (Chronic Pain)

Back in 2021, CMS introduced a new add-on code for outpatient Evaluation and Management services, G2211. After a 3-year delay in implementation, the code is finally becoming active on 1/1/24. When appropriate, G2211 is to be billed in addition to the E/M code for the visit, with both receiving separate payment. The descriptor is listed below:

G2211 Visit complexity inherent to evaluation and management associated with medical care services that serve as the continuing focal point for all needed health care services and/or with medical care services that are part of ongoing care related to a patient’s single, serious condition or a complex condition. (Add-on code, list separately in addition to office/outpatient evaluation and management visit, new or established)

MIPS Traditional and MVP Reporting Options

Beginning in CY 2023, Anesthesia providers were offered an optional new “track” to report MIPS Quality measures. Unlike the traditional reporting methodology (where you submit your top 6 quality measures), a new program was introduced called MIPS Value Pathways (MVPs). In order to participate, your practice’s Quality Payment Program (QPP) Security Official will need to complete the MVP Registration during the window of April 3rd through November 30th. For assistance with this process, please contact your MSN Client Services Representative.

Patient Safety and Support of Positive Experiences with Anesthesia (MVP ID: G0059) Quality Measure Options:

  •  404 Anesthesiology Smoking Abstinence (Outcome)
  • 424 Perioperative Temperature Management (Outcome)
  • 430 Prevention of Post-Operative Nausea and Vomiting (Process)
  • 463 Prevention of Post-Operative Vomiting – Pediatrics (Process)
  • 477 Multimodal Pain Management (Process)
  • AQI48 Patient-Reported Experience with Anesthesia (Patient Reported Outcome)
  • AQI69 Intraoperative Antibiotic Redosing (Process)

*MVP Reporting Requirements: Select 4 quality measures from the list above with at least one outcome measure.

Other Quality Payment Program Proposals for 2024

MIPS Performance Threshold: Increase to 82 Points (used to determine incentive payments and penalties).

Composite Score Components: Unchanged (Quality 30%, Cost 30%, Promoting Intraoperability 25%, Improvement Activities 15%).

Data Completeness: Increase to 75% for 2024-2026 Reporting Periods.

New Quality Measures: ABG44 (Low Flow Inhalational General Anesthesia), EPREOP31 (Intraoperative Hypotension among Non-Emergent Non-Cardiac Surgical Cases, Q487 (Screening for Social Drivers of Health).

Hal Nelson, Vice President Anesthesiology Services

CANPC

VP of Anesthesiology Services

Hal has 30+ years of experience on both the payor and RCM side, with a focus in Anesthesia. He formerly worked as a senior claims approver at United Healthcare, as well as a compliance officer for multiple national anesthesia billing companies. His broad-based experience ensures that MSN clients have a resource for documentation and billing issues. His past speaking engagements include ASA, MGMA, Dartmouth, and Johns Hopkins.

This educational guide was prepared as a tool to provide education for documentation and coding. It is not intended to affect clinical treatment patterns. The material provided is for informational purposes only. Efforts have been made to ensure the information within this document was accurate on the date of distribution. Reimbursement policies vary from insurer to insurer and the policies of the same payer may vary within different U.S. regions. All policies should be verified to ensure compliance. CPT® codes, descriptions and other data are copyright of the American Medical Association (or such other date of publication of CPT®).All Rights Reserved. CPT® is a registered trademark of the American Medical Association. Proprietary and confidential document.  All rights reserved. No part of this document may be reproduced or used in any manner without the written permission of MSN Healthcare Solutions, LLC.

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