CMS released the calendar year 2024 Medicare Physician Fee Schedule final rule yesterday, November 2, 2023. The proposals from July mostly survived. The conversion factor for 2024 is $32.74, down $1.15 or about 3.4% from the 2023 factor of $33.89. The G2211 visit complexity add-on is payable from January 1. And, in the one significant reversal, CMS did not raise the MIPS performance threshold to 82 points as proposed; it stays at 75 for the 2024 performance year.
Now the practical part begins. The rule takes effect January 1, 2024, which gives practices eight working weeks that include Thanksgiving and the December holidays. Here is what we think needs to be done, roughly in order.
Key takeaways
- The 2024 conversion factor is final at $32.74, a 3.4% cut. Every contract that floats with the current Medicare schedule moves with it on January 1.
- G2211 is payable from January 1 with office and outpatient E/M visits, but not when the visit carries modifier 25. Build the claim edit and train the providers before the first January visit.
- The MIPS performance threshold stays at 75 points for 2024; the proposed jump to 82 was not finalized.
- Caregiver training codes 97550 to 97552 are payable, and split or shared visit flexibility continues through 2024.
What was finalized
| Item | Final policy for 2024 |
|---|---|
| Conversion factor | $32.74, a 3.4% decrease from $33.89 |
| G2211 | Payable with office and outpatient E/M visits from January 1, 2024; not payable when the visit carries modifier 25 |
| Split or shared visits | Current flexibility (substantive portion by history, exam, MDM or more than half the time) continues through 2024 |
| Caregiver training services | CPT 97550, 97551 and 97552 assigned active payment status |
| MIPS performance threshold | Remains 75 points for the 2024 performance year (proposal of 82 not finalized) |
| Telehealth | Flexibilities extended by Congress through December 31, 2024 continue; CMS aligned its policies accordingly |
| SDOH risk assessment | New payment for a standardized social determinants of health risk assessment furnished with an E/M or annual wellness visit |
CMS has estimated that G2211 would be billed with about 38% of all office and outpatient E/M visits at first and roughly 54% once fully adopted, which tells you how broadly the agency expects it to be used, and how closely it will watch the pattern. Those estimates are also why the conversion factor fell as far as it did: paying for G2211 inside a budget-neutral pool takes money from every other service.
Week 1 to 2: fee schedules and contracts
Load the 2024 Medicare fee schedule with the final conversion factor and RVUs as soon as your practice management vendor or your MAC publishes the file. Then read every commercial and Medicare Advantage contract for how its rates reference Medicare. A contract that says "the Medicare Physician Fee Schedule in effect on the date of service" drops 3.4% on January 1. A contract fixed to a named year does not. Know which you have before the first January remittance, or you will spend February arguing about underpayments that are not underpayments. We covered the loading mechanics in how to load payer fee schedules.
Keep the 2023 rate rows in the system with an end date of December 31, 2023. Claims with 2023 dates of service will keep paying into February and March, and the variance report needs the 2023 expected amount to judge them.
Week 2 to 4: G2211 in the system and in the notes
Add G2211 to the charge master with a January 1 start date. Build a claim edit that flags G2211 when the same claim carries an E/M with modifier 25; under the final rule that combination is not payable, and auto-submitting it produces a predictable denial. Then meet with providers. The code is for visits where the practitioner is, or intends to be, the continuing focal point for the patient's care, or is managing a single serious or complex condition over time. The note has to support that. A statement in the assessment that the practice is managing the patient's chronic conditions longitudinally is the kind of documentation that holds up; a template checkbox that appears on every visit is not.
Two more decisions. Whether to bill G2211 for Medicare Advantage and commercial patients, which depends on each payer's policy (many have not announced one), and how to handle the small patient coinsurance the add-on creates for traditional Medicare patients. Patients will ask why their bill has a code they do not recognize. Have an answer ready for the front desk.
A worked example of the money involved. G2211 carries a national payment in the neighborhood of $16 at the 2024 conversion factor, before geographic adjustment. A primary care physician with 3,200 established Medicare visits a year who documents the longitudinal relationship on, say, 60% of them adds roughly 1,900 units, or about $30,000 in allowed amounts, of which Medicare pays 80% and the patient or supplement owes the rest. The same physician's share of the conversion factor cut on $600,000 of Medicare allowed amounts is about $20,000. For that physician the add-on more than offsets the cut, if the documentation habit is real. For a procedural specialist with few qualifying visits, nothing offsets it.
Week 3 to 5: MIPS for 2024
The threshold staying at 75 is relief, not exemption. Clinicians and groups scoring below 75 in 2024 face a negative adjustment in 2026, up to 9%. Confirm your 2024 participation status with the QPP lookup when it updates, review the quality measures you reported in 2023 for any removed or substantially changed for 2024, and look at the MIPS Value Pathways available for your specialty. CMS finalized five new MVPs for 2024, bringing the total to 16. MVPs remain optional for 2024, but CMS has been clear about the direction, and a practice that reports an MVP in 2024 voluntarily learns the format while the stakes are lower.
Week 4 to 6: therapy practices and caregiver training
Physical, occupational and speech therapy practices should add 97550, 97551 and 97552 with January 1 start dates and build the documentation template: the patient's consent to caregiver training without the patient present, the caregiver's identity, the training content, and the time. These are time-based codes and the minutes have to be in the note. Primary care and specialty practices should also look at the new community health integration and principal illness navigation services CMS finalized, which pay for auxiliary staff time spent addressing social needs and navigating serious illness under a practitioner's direction. They require an initiating visit and consent, and they are worth a look for practices that already employ care coordinators.
Week 6 to 8: budget and the front desk
Rebuild the 2024 revenue budget with the final conversion factor and a conservative G2211 assumption. A practice with $1.4 million in Medicare and Medicare-linked allowed amounts is looking at roughly $48,000 less from the conversion factor alone; the G2211 offset depends entirely on the visit mix and the documentation habit, and we would not count on more than a fraction of that in the first quarter. Then brief the front desk on the January deductible reset. CMS announced on October 12 that the 2024 Part B deductible is $240, up from $226, and the standard premium is $174.70; the $240 figure belongs in the estimate tool before the first January visit, along with the G2211 patient question above.
Questions we hear
Could Congress still change the cut?
Congress partially offset the cuts for 2021, 2022 and 2023, each time late in the year or after it began. Legislation has been introduced again. We would plan on $32.74 and treat any relief as an upside.
Can a specialist bill G2211?
Yes, if the relationship fits. A specialist who is the ongoing manager of a patient's serious or complex condition qualifies. A specialist seeing a patient for a one-time procedure or a consult without an ongoing role does not. CMS did not restrict the code by specialty; it restricted it by relationship.
Is the split or shared "substantive portion" rule finally settled?
Not permanently. CMS extended the current flexibility through 2024 and said it will continue to consider the policy. For 2024, the practitioner who performs the history, the exam, the medical decision making, or more than half the time can bill the visit in a facility setting. Document which one.
What to do this month
- Read the CMS fact sheet for the final rule. Skip the full rule unless you have a specific question.
- Book the provider meeting on G2211 for the first week of December, with the practice's own 2022 E/M data in hand.
- Ask each Medicare Advantage and commercial payer, in writing, whether it will recognize G2211 and how its 2024 rates move with the conversion factor.
- Confirm the practice management vendor's date for the 2024 fee schedule and code update, and build the G2211 with modifier 25 claim edit.
- If the billing team cannot absorb the January changeover on top of year-end, talk about outsourced billing now, not on January 15.
