On July 13, 2023, the Centers for Medicare & Medicaid Services (CMS) issued a proposed rule that announces and solicits public comments on proposed policy changes for Medicare payments under the Physician Fee Schedule (PFS), and other Medicare Part B proposals, effective on or after January 1, 2024.
By factors specified in law, overall payment rates under the PFS are proposed to be reduced by 1.25% in CY2024 compared to CY2023. The proposed CY2024 PFS conversion factor is $32.75, a decrease of $1.14 (or 3.34%) from the current CY2023 conversion factor of $33.89. From an historical perspective, CMS originally finalized the CY2023 conversion factor at $33.06, a 4.47% cut from the CY2022 conversion factor. That cut was ultimately reversed by Congress and the CY2023 conversion factor increased to $33.89 as a direct result of passage of the Consolidated Appropriations Act, 2023, which included among other things, changes to the Medicare payment program, sequestration requirements, and coverage of telehealth services.
CMS invites providers to communicate directly with the agency during an open comment period following the publication of the proposed rule. This affords every provider an opportunity to voice an opinion on the proposed changes for the upcoming year. While this notice focuses on two new procedure codes related to audiological services for implantable bone conduction hearing devices, Cochlear Americas encourages providers to engage with their professional societies for updates on advocacy efforts related to their specialties, practice implications, and participation opportunities. Would you like to see permanent telehealth coverage to integrate this service into your current practice? Have you dealt with claim denials for non-acute hearing services reported with the AB modifier? Bipartisan legislation, the Medicare Audiology Access Improvement of 2023, was just reintroduced to address these issues and more. This is the time to shape the future of hearing care delivery. For more information on the CY2024 proposed rule and how you can join the conversation, please visit any of the professional society’s websites (AAA, ADA , and ASHA).
Auditory Osseointegrated Implant Services:
CMS proposed two new Current Procedural Terminology (CPT®) codes to report services related to the diagnostic analysis, programming, and verification of an auditory osseointegrated sound processor. As seen below, the placeholder ‘X’ is utilized until the final CPT code is published in the final rule, expected later this calendar year. Additionally, CMS proposed acceptance of the Relative Value Scale Update Committee (RUC) recommended inputs for both work and direct practice expense components. In 2022, CMS published a list of audiological services for non-acute hearing conditions to which the AB modifier may be appended to indicate the provision of the service without a physician/nonphysician practitioner (NPP) referral. CMS proposed to include both CPT 926X1 and 926X2 on this list of services in CY2024.
To share positions on any proposals made, providers may communicate with CMS during the public comment period. To be assured consideration, comments must be received at one of the addresses provided below, no later than 5 p.m. on September 11, 2023. Commenters may refer to file code CMS-1784-P and submit in one of the following three ways:
- Electronically. You may submit electronic comments on this regulation to https://www.regulations.gov . Follow the “Submit a comment” instructions.
- By regular mail. You may mail written comments to the following address ONLY: Centers for Medicare & Medicaid Services, Department of Health and Human Services, Attention: CMS-1784-P, P.O. Box 8016, Baltimore, MD 21244-8016.
- By express or overnight mail. You may send written comments to the following address ONLY: Centers for Medicare & Medicaid Services, Department of Health and Human Services, Attention: CMS-1784-P, Mail Stop C4-26-05, 7500 Security Boulevard, Baltimore, MD 21244-1850.
Cochlear Americas is pleased to partner with all hearing care professionals. For more information, please visit our Reimbursement HUB, designed specifically for healthcare providers.
Before you go, please provide feedback on your initial impressions regarding the proposed rulings by completing this short survey.
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