DHPA today submitted a comment letter to Centers for Medicare & Medicaid Services on the Medicare Physician Fee Schedule (MPFS) Proposed Rule for Calendar Year 2024.
DHPA’s comments on the Proposed Rule focus on four issues impacting Medicare beneficiaries’ access to high-quality, affordable care for gastrointestinal conditions and diseases. DHPA urged CMS to take the following actions as it finalizes the MPFS for CY 2024:
- Analyze the risks, resources, and complexity of administration of particular drugs when assigning codes and reimbursement to such drug’s administration, rather than merely looking at whether the drug treats cancer or not. From the perspective of independent gastroenterology practices that care for patients with Crohn’s disease and ulcerative colitis, it is particularly important that CMS set reimbursement for the administration of Entyvio® (J3380), Stelara® (J3358), Tysabri ® (J2356), and Cimzia® (J0717) consistent with the reimbursement provided under the “Chemotherapy and Other Highly Complex Drug or Highly Complex Biological Agent Administration Current Procedural Terminology (CPT) Codes” (CPT 96401-96549).
- Make permanent CMS’s definition of “substantive portion” for split (shared) visits in the facility setting that was in effect for CY 2022 and remains in effect for CY 2023 or, at the very least, redefine “substantive portion” to include either more than 50% of the medical decision-making by the physician or NPP or more than 50% of the time spent by the physician or NPP.
- Make permanent the flexibility to meet the “immediate availability” requirement for direct supervision via use of two-way audio/video communications technology, unless CMS finds that for a specific service there is a patient safety or over-utilization concern that requires on-site supervision. At a minimum, CMS should extend the flexibility through ecember 31, 2024, so that this flexibility aligns with other telehealth flexibilities.
- Support Congressional efforts to provide the physician community with relief from impending payment cuts set to take effect on January 1, 2024.
Click here to read the full letter >>