Anesthesia Coding Alert

Significant payment cuts will harm seniors’ access to surgical care, warns ASA.

Medicare providers will need to tighten their belts next year, as another year of payment cuts is around the bend. But on the bright side, further advancements in health equity and expanded access to healthcare are on the horizon.

Context: On Nov. 16, the Centers for Medicare & Medicaid Services (CMS) unveiled the calendar year (CY) 2024 Medicare Physician Fee Schedule (MPFS) final rule. Per usual, there’s a lot to unpack in the 1,230 pages published in the Federal Register, but one hot topic at the forefront is the confirmed reductions to both the MPFS and anesthesia conversion factors (CFs) in the coming year.

Let’s take a look at the policies that will likely have the greatest impact on your Medicare reimbursement.

Beware, Conversion Factor Reductions Confirmed

In the final rule, CMS opts to reduce the overall payment rate by 1.25 percent and the MPFS CF by 3.37 percent or $1.15, decreasing the amount from $33.89 (CY 2023) to $32.74 (CY 2024). For anesthesia providers, this CF will come into play when submitting claims for non-anesthesia services such as postoperative pain procedures, invasive lines, and ultrasound guidance.

Within the MPFS, CMS has also finalized significant Medicare payment cuts to the anesthesia (ACF), the Resource-Based Relative Value Scale (RBRVS) CF, and the bundling of certain procedure codes that will result in anesthesiologists, critical care, and pain medicine physicians receiving less pay in 2024. The agency has set the 2024 ACF at $20.4349. This reflects a $0.69 drop from the 2023 ACF of $21.1249, or a 3.27 percent reduction. The 2024 finalized RBRVS CF is $32.7442, representing a decrease of 3.37 percent from the 2023 RBRVS of $33.8872.

Analysis: The final 2024 ACF ended up being even less — if ever so slightly — than the proposed ACF of $20.4370. With the final number coming in just a tad lower than what was originally suggested, some may perceive this as adding insult to injury.

Many hoped CMS would leave the CFs, at the very least, status quo for CY 2024, but with the final rule’s release, that didn’t happen. However, Congress may yet intervene to cut that decrease to closer to 2 percent, as they have in years past.

Note: For CYs 2021, 2022, and 2023, Congress stepped in with last-minute legislation to circumvent the cuts, but even its intervention was minuscule.

Assess Specialty Impact — Anesthesia, Pain Medicine

According to CMS, the 2024 payment increases for primary care and other direct patient care providers meant that payment cuts must occur in other specialties to achieve budget neutrality. While specialties like internal medicine and family practice will see reimbursement increases, others are facing cuts, including anesthesiology (-2 percent) and nurse anesthetists (-2 percent). For some, like interventional pain management (0 percent), it’s a wash.

Actual payment rates are impacted by a range of policy changes related to physician work, practice expense, and malpractice RVUs. You’ll find CMS’ estimates of these changes in Table 118 in the final rule.

Know Controversial Complex Add-On Code To Take Effect

CMS is moving forward with the implementation of add-on code G2211 (Visit complexity inherent to evaluation and management associated with medical care services …); it will go into effect, as expected, on Jan. 1, 2024. The agency also finalized a utilization assumption of 38 percent for G2211, as proposed.

Impact: Nearly 90 percent of the negative budget neutrality adjustment to the CF that anesthesiologists and other physicians will face in 2024 is attributable to the new bonus payment for G2211.

The American Society of Anesthesiologists (ASA) “vehemently opposed the implementation of this code because it is duplicative of the work already accounted for by existing codes and will inappropriately result in overpayments for some physicians, paid for by underpayments for other important services, including anesthesia care,” said ASA President Ronald L. Harter, MD, FASA, in a press release.

Preview New Pain Medicine Code, Valuation

Pain medicine physicians will soon be able to get paid by Medicare for providing percutaneous sacroiliac (SI) joint arthrodesis using intra-articular implants such as bone allografts or synthetic devices. New Category I code 27278 (Arthrodesis, sacroiliac joint, percutaneous, with image guidance, including placement of intra-articular implant(s) …) will replace the current Category III code 0775T (Arthrodesis, sacroiliac joint, percutaneous, with image guidance …). For CY 2024, CMS has finalized a work RVU of 7.86 for 27278.

Hear What Industry Leaders Are Saying

“Once again, Medicare payments to physician practices will be drastically cut, with anesthesiologists, critical care, and pain medicine physicians being disproportionately impacted … Congress must act before the end of the year to prevent these deleterious cuts from negatively impacting the Medicare patient population’s access to care,” Harter proclaimed.

“A critical, immediate fix that Congress can do is to block the new G2211 payment code that CMS will launch in its 2024 [M]PFS, which creates instability and imbalance in the payment system. This can be done efficiently by Congress with no impact to the Medicare budget. Congress could also pass harmless legislation to protect other important Medicare services from the G2211 generated cuts,” he added.

AMA weighs in: Physician payments have been on a downward spiral for years — and that’s a problem, warns the AMA. “When adjusted for inflation, Medicare physician payment already has effectively declined 26 percent from 2001 to 2023 before additional inflation and these cuts are factored in. Physicians are one of the only providers without an automatic inflationary increase,” explained AMA President Jesse M. Ehrenfeld, MD, MPH, in a release.

“This is almost biblical in its impact,” he argued. “Seven lean years that include a pandemic and rampaging inflation. Physicians need relief from this unsustainable journey.”