CMS Finalizes 2024 Medicare Physician Fee Schedule

November 3, 2023

On November 2, 2023, the Centers for Medicare & Medicaid Services (CMS) issued the Notice of Final Rulemaking for the 2024 Medicare Physician Fee Schedule (MPFS). Here are the key provisions affecting ABA services:

Proposed Carrier Pricing of ABA CPT Codes

CMS extended carrier pricing of the CPT codes for adaptive behavior/ABA services through 2024. That means that providers will need to continue negotiating reimbursement rates with payers.

Telehealth Approval of CPT codes

CMS reported receiving 9 applications to add certain CPT codes to the list of those that are approved for telehealth delivery on a permanent basis. Two of those applications pertained to codes for therapeutic services, which include ABA services. In the proposed rule, CMS stated that they believe adding those codes to the permanent Medicare telehealth list would create confusion because CMS does not have the authority to expand the list of eligible Medicare telehealth practitioners to include therapists after 2024 per regulation 87 FR 69449 – 69451 of the federal Consolidation Appropriations Act (CAA) of 2023. The CAA extended current telehealth flexibilities through the end of 2024. Therefore, CMS has finalized their proposal to retain all CPT codes for therapeutic services in telehealth Category 3 (temporary) through December 31, 2024. That includes the adaptive behavior/ABA services codes (97151-97158, 0362T, 0373T).