Highlights of the 2024 Physician Fee Schedule: Another Step Closer to Value-Based Care in Physician Billing Services

After years of announcements and speculation, 2024 is shaping up to be a year where CMS takes significant steps in making value-based care a reality. One area where they’re taking the most action has a direct impact on physician billing services. 

In early November, the agency issued the calendar year (CY) 2024 Medicare Physician Fee Schedule (PFS) final rule to support equity, growth, and alignment through value-based care. The final rule includes major changes that cover ACO digital measurement, financial benchmarking methodology, and efforts to encourage ACO participation in care for medically complex and high-cost beneficiaries. I’ve pulled some highlights, which should be of interest to providers engaged in physician billing services. 

Increasing participation in accountable care models in underserved communities. 

These actions entail advance investment payments, a smoother transition to performance-based risk, and are intended to support smaller providers in underserved and rural settings who need more time to make the transition to two-sided risk – meaning they’re acknowledging that forcing ACOs to adopt was actually a barrier, slowing participation in the Shared Savings Program. 

Strengthening program participation by reducing the effect of ACO performance on historical benchmarks, addressing market penetration, strengthening incentives for ACOs serving medically complex and high cost of care populations. 

This element includes a prospective external factor in growth rates, adjusting ACO benchmarks to account for prior savings for renewing and re-entering ACOs, and reducing the impact of the negative regional adjustment through two proposed policy changes, among others. 

Transitioning ACOs to all payer quality measure reporting and adjusting for health equity.

This effort will involve a sliding scale approach for determining shared savings and losses, a health equity adjustment, addressing MIPS quality performance category score corrections, and clarification around the use of unweighted MIPS quality performance category scores. 

Other areas CMS is addressing include reducing administrative burden for ACOs and updates to the ACO beneficiary assignment methodology. I encourage any provider thinking about their relationship with physician billing companies to review this fact sheet for a complete list of the changes, and to contact us at 3Gen Consulting with questions you have or to access insights from our experienced team.