CMS Issues 2024 Proposed Medicare Physician Fee Schedule
July 19, 2023
On July 13, 2023 the Centers for Medicare & Medicaid Services (CMS) issued the Notice of Proposed Rulemaking (NPRM) for the 2024 Medicare Physician Fee Schedule (MPFS). Here are the key provisions affecting ABA services:
Proposed Carrier Pricing of ABA CPT Codes
CMS proposes to extend 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 receiving9 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. In the NPRM, CMS stated thatthey believe adding those codes to the permanent Medicare telehealth list would create confusion. As in the final rules for 2023, CMS noted that they do not have the authority to expand the list of eligible Medicare telehealth practitioners to include therapists after 2024 (citing regulations 87 FR 69449 – 69451) because the federal Consolidation Appropriations Act (CAA) of 2023 did not change the list of practitioners who can furnish and bill for telehealth services permanently. Rather, the CAA extended current telehealth flexibilities through the end of 2024. Therefore, CMS proposes to retain all CPT codes for therapeutic services as telehealth Category 3 (temporary) through December 31, 2024. That includesthe adaptive behavior/ABA services codes (97151-97158, 0362T, 0373T).
We anticipate that the final rules for the 2024 MPFS will be published in November and will post updates at that time.