On November 2, the Centers for Medicare & Medicaid Services (CMS) released the final rule updating policies for the Calendar Year (CY) 2024 Medicare Physician Fee Schedule. The agency finalized several significant policy changes, including making payment for HCPCS code G2211, an add-on code for services associated with complex patient care, and continuing to pay for telehealth services at the non-facility rate when the place of service code indicates the originating site is the patient’s home. In addition, the agency finalized work and practice expense RVUs for CPT codes used by urologists, which the AUA advocated for through RUC process. A fact sheet and press release are also available for review.

2024 Conversion Factor

The conversion factor for 2024 is set to decrease by approximately 3.37% from $33.89 to $32.74. Without Congressional action, CMS cannot implement policy to avert the cut to the conversion factor. The AUA submitted detailed comments on how continued cuts to physician payment affect our specialty and has been actively advocating for Congress to pass legislation averting this cut and authorizing positive updates to the conversion factor.

Impact to the Specialty of Urology

Table 118, CY 2024 PFS Estimated Impact on Total Allowed Charges by Specialty, outlines the changes to payments for specialties based on the policies in the rule and shows that urology is projected to see an increase of 1% in overall Medicare payments. Note that impact to group practices and individual physicians varies based on practice type, mix of patients and the types of services provided to those patients.

CMS Accepted RUC Recommendations for New and Revised CPT® Codes

Through the work of the AUA’s CPT and RUC advisors and staff and AUA member responses to RUC surveys, the Association was instrumental in valuing new and revised CPT codes used to report services for cystourethroscopy and neurostimulator services for bladder dysfunction.

CMS finalized the RUC-recommended work RVU of 3.10 for new CPT code 52284 (Cystourethroscopy, with mechanical urethral dilation and urethral therapeutic drug delivery by drug coated balloon catheter for urethral stricture or stenosis, male, including fluoroscopy, when performed). The code will be available for use January 1, 2024.

Additionally, CMS accepted the RUC-recommended work RVUs for neurostimulator services associated with bladder dysfunction. Those services are described by CPT codes 64590 (Insertion or replacement of peripheral, sacral, or gastric neurostimulator pulse generator or receiver, requiring pocket creation and connection between electrode array and pulse generator or receiver) and 64595 (Revision or removal of peripheral, sacral, or gastric neurostimulator pulse generator or receiver, with detachable connection to electrode array) and will have work values of 5.10 and 3.79 respectively.  

Telehealth

CMS continues to support the use of telehealth in the Medicare program and has finalized policies that will allow greater beneficiary access to virtual services. Based on the final rule, the telehealth originating site requirement will continue to be waived through the end of 2024, allowing patients to receive care at any site, including their home. Payment for telemedicine services provided to patients in their homes will continue to be paid at the non-facility rate. For the services delivered by urologists, telehealth payment parity will only continue if their patients are eligible to receive services in their homes, which is dependent on the originating site requirement waiver. The AUA continues to advocate for Congress to pass legislation either making the waiver permanent or extending it beyond December 31, 2024. The agency also finalized that direct supervision may be provided through real-time audio and video interactive communications through December 31, 2024.

Evaluation and Management Complex Care Add-on HCPCS Code

The agency will finally implement the controversial HCPCS G2211 add-on code ((Visit complexity inherent to evaluation and management associated with medical care services that serve as the continuing focal point for all needed health care services and/or with medical care services that are part of ongoing care related to a patient's single, serious condition or a complex condition. (Add-on code, list separately in addition to office/outpatient evaluation and management visit, new or established)).

The code was originally proposed for implementation in 2021, but Congress delayed it for three years. In this rule, the agency lowered the code’s utilization estimate and provided parameters for when the code may be billed, including prohibiting its use with modifier -25, to lessen the impact on payment for other services. The AUA will continue to evaluate the impact this code will have on members and work with our collaborative partners to determine next steps.

Split (or Shared) Evaluation and Management Visits

After several years of consideration, CMS finalized a new split (or shared) visit policy. Based on comments received from the AUA and other stakeholders, the new definition of “substantive portion” of a split (or shared visit) will be determined by more than half of the total time spent by the physician or nonphysician practitioner performing the visit or a substantive part of the medical decision making. This policy is now consistent with the billing requirements for other evaluation and management services.