The MPFS CY24: What Does the Proposed Rule Mean for Audiology Payments?

The proposed rule for the Medicare Physician Fee Schedule (MPFS) for calendar year 2024 (CY24) shows another year of Medicare cuts for most providers, as reflected in the extensive red of the audiology code table included with a recent update from the Academy. The projected impact is a -2 percent cut overall for audiology codes on top of the conversion factor. However, it is not just audiology facing reduced payments.

The conversion factor impacts all disciplines because it is across the fee schedule with a decrease predicted of 3.36 percent, along with the third year of a phase-in of clinical labor cuts and other adjustments for budget neutrality that are part of current law.

The conversion factor (CF) is the number of dollars that are assigned to the relative value unit (RVU) of a billing code. It translates to a national dollar multiplier, applied with a geographic adjuster, to convert the adjusted RVU to a payment. A complex calculation based on the state of the U.S. economy, the number of Medicare beneficiaries, money spent in prior years, and changes in Medicare regulations determines the CF. Each year, the CF is adjusted for things such as budget neutrality and the Medical Economic Index. The proposed CY24 PFS conversion factor is $32.75, a decrease of $1.14 over CY23.

The proposed CF update is based on three factors:

1. A statutory 0 percent update scheduled for the PFS in CY 2024 under MACRA.
   
   
2. An approximately 2.17 percent decrease due to a budget neutrality adjustment, of which 90 percent can be attributed to the implementation of complexity add on code G2211 and the remaining 10 percent can be attributed to other proposed valuation changes such as the Year 3 update to clinical labor pricing in practice expense and the proposed adjustment to certain behavioral health services.
   
   
3. The expiration of 1.25 percent of the 2.5 percent positive adjustment to the CF the Congressional omnibus legislation provided for in CY 2025, which it reduced to 1.25 percent for CY 2024. 

Because most of the cuts are the result of legislation, the Centers for Medicare and Medicaid Services (CMS) can only do so much to improve the fee schedule. The Academy will continue to work with other disciplines to lobby Congress for long-term payment reform to resolve the ongoing cuts and untenable rates for audiology codes. One piece of good news for audiology in the fee schedule is that CMS opted to accept the RUC valuations for the new Auditory Osseointegrated Device (AOD) codes.

CMS provides fact sheets that help to provide explanation and detail on the proposed rule and payment system.