On July 13, the Centers for Medicare & Medicaid Services (CMS) released the Medicare Physician Fee Schedule (MPFS) proposed rule for CY 2024 (CMS-1784-P). This rule updates payment policies and payment rates for Part B services furnished under the MPFS, as well as makes changes to the Quality Payment Program (QPP). The AUA submitted comments on the proposed rule on September 8.

Related: View the AUA’s Summary on the proposed rule for the CY 2024 Medicare Physician Fee Schedule

AUA’s comment letter specifically addresses the following:

• Proposed Valuation of Specific Codes for CY 2023
• Conversion Factor Update
• Delaying the Implementation of the Rebased Medicare Economic Index
• Evaluation and Management (E/M) Services
• Split/Shared Services
• Telehealth Services and Remote Monitoring and Therapeutic Services
• Services Addressing Health-Related Social Needs
• Drugs and Biologics Paid Under Medicare Part B
• Quality Payment Program Proposed Provisions

The AUA placed particular emphasis on CMS’ proposed valuation of urology-specific codes for Neurostimulator Services (CPT Codes 64590 and 64595), thanking the agency for proposing the Relative Value Scale Update Committee’s (RUC) recommended work and Practice Expense (PE) relative value units (RVUs). AUA members actively participated in the RUC survey processes used to support the values recommended for these codes, and the AUA is grateful to see them proposed as recommended and urges the agency to finalize these values.

The AUA also urged CMS to expand telehealth flexibilities beyond 2024, reiterated the need to mitigate cuts to physician payment, and the importance of using the most updated data collected to rebase the Medicare Economic Index (MEI), which is currently proposed to be delayed in implementation due to the AMA’s PPI survey, in which AUA members are participating. The AUA previously met with CMS to discuss the proposed rule on August 29.