As usual, the new year brings important changes in the Medicare program.
Here’s the lowdown for 2024.
Q. What coding changes will we see in 2024?
A. First, there are no code changes for evaluation and management (E/M) codes, but there are changes to the descriptions. As you know, deciding which E/M code to bill can be determined either by medical decision making (MDM) or by time. For ophthalmologists, most visits are coded based on MDM, but time is a factor in some cases.
In years past, CPT simply assigned time ranges to each E/M code. Now, the description has been changed to include minimum physician time. Remember that these times now count not just face-to-face time but also other physician time on the date of the encounter.
This is not a coding or policy change, but the CPT definitions have caught up with the changes implemented in 2021. The descriptions now read:
“When using total time on the date of the encounter for code selections, XX minutes must be met or exceeded.”
The amount of time varies, of course, according to code, as follows:
Ophthalmology gets only one new Category I CPT code in 2024:
- 67516 Suprachoroidal space injection of pharmacologic agent (separate procedure)
This replaces the Category III code:
- 0465T Suprachoroidal injection of a pharmacologic agent (does not include supply of medication)
There are a lot of new Category III codes, but none that are pertinent to ophthalmology.
Q. What’s happening with physician reimbursement?
A. The 2024 Medicare Physician Fee Schedule (MPFS) Final Rule was released on November 2, 2023 and published in the Federal Register on Nov. 16, 2023.
The 2024 MPFS conversion factor is $32.7442, down 3.36% ($1.15) from $33.89 in 2023. This reflects the following:
- The 0% update adjustment factor that was part of the Medicare Access and CHIP Reauthorization Act of 2015 (MACRA),
- A 1.25% update provided under the Consolidated Appropriations Act, 2023, and
- A budget neutrality adjustment of -2.18%; this is primarily due to the implementation of the complex care add-on code G2211.
CMS estimated the financial impact by specialty in the Final Rule. According to CMS, ophthalmology will see an overall reduction of approximately 1%.
Q. What is the complex care add-on code?
A. New HCPCS code G2211 is defined as: 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. So far, CMS has not issued instructions for use of this code. However, the CMS website includes a listing of pertinent “practitioner primary care specialties,” and it does not include ophthalmology (or optometry). So, it does not appear that the new code will be helpful to ophthalmology in recovering any of the MPFS decrease (www.cms.gov/priorities/innovation/data-and-reports/2022/pcf-first-eval-rpt).
Q. What about changes to specific procedures?
A. Unless Congress steps in again at the last minute to change payment levels, the expected national allowed amounts for common ophthalmic codes are as seen in Table 1. For most codes, the allowable is reduced by a small amount. Among common ophthalmic tests, only fluorescein angiography increased.
For most ophthalmic surgical procedures, the Final Rule contained reductions in the Medicare payment rates for 2024. See some examples in the Table 2, below. OM
