ACG, AGA and ASGE submitted recommendations to CMS for improving practice issues and payment rates for gastroenterologists next year.

Our comments were in response to CMS’ 2024 proposed rules for the Medicare Physician Fee Schedule, Hospital Outpatient Prospective Payment System and Ambulatory Surgery Centers. We expect CMS to release the final Medicare rules later this fall.

Our key messages to CMS

  • Prevent the 3.36% cut payments to physicians: CMS overestimated utilization of a new E/M visit complexity code G2211, which will result in cuts to all other codes in 2024. CMS needs to reassess its utilization assumptions for G2211, which could help mitigate cuts to 2024 physician payments.

  • Continue to cover telemedicine: Kudos to CMS for covering audio-only communications until the end of 2024 and for allowing telehealth visits to originate anywhere in the U.S. (including the individual’s home). CMS should continue coverage beyond 2024 with payment rates matching those of office/outpatient E/M visits.

  • Regularly update practice expense (PE) data: Update indirect PE data to reflect today’s costs of running a practice—”current” values are based on 2006 data! We support the AMA’s PE data collection effort. See information below on how you can help.

  • Expand the number of GI tests covered in the ASC setting: To lower costs, add 15 GI diagnostic tests to the list allowed in the ASC setting. These tests can be safely performed in ASCs and moving them out of the hospital setting results in savings.

  • Increase facility payment for POEM: To better align with the procedure’s cost, place CPT code 43497 for Peroral Endoscopic Myotomy (POEM) into a higher-level APC (5331 – Complex GI procedures) with a facility payment of $5,455.74.

  • Finalize the current split/shared visits policy: While CMS fortunately paused its plan to define the “substantive portion” of a visit as simply more than half the total time spent with the patient, the definition is still in flux. We advocate CMS allow facilities to use either one of three key components (history, exam or medical decision making) OR more than half of the total time spent to determine who will bill for the visit. There will not be any changes in 2024.

Help improve practice expense payments!

Our societies support the AMA’s Physician Practice Information (PPI) survey to better understand costs providers currently face. If you are contacted by Mathematica, the independent research company conducting the survey, please participate.

This is an opportunity for you, as providers, to speak up and support physician payment advocacy. CMS currently uses outdated data from 2006 to develop PE relative values, the Medicare Economic Index and resulting physician payments.

Practices and individual physicians are randomly selected to participate in this study. Participants selected will receive a short patient care survey from their practice or from Mathematica. Be sure to complete the survey if you are selected – this is critical for its success and to ensure that practice expenses and patient care hours are accurately reflected.  

Read our comment letters to CMS:
Medicare Physician Fee Schedule (MPFS)
Medicare Hospital Outpatient Prospective Payment System (OPPS) & Ambulatory Surgical Center (ASC)

GI societies’ summaries (July 2023): 
Medicare Physician Fee Schedule (MPFS) 
Medicare Hospital Outpatient Prospective Payment System (OPPS) & Ambulatory Surgical Center (ASC).

CMS Hospital Outpatient and ASC Proposed Rule and Fact Sheets
2024 Medicare OPPS/ASC Proposed Rule
2024 Medicare OPPS/ASC Fact Sheet