On July 13, 2023, the Centers for Medicare & Medicaid Services (CMS) released its Calendar Year (CY) 2024 Medicare Physician Fee Schedule (PFS) proposed rule, (PDF) which includes proposals related to Medicare physician payment and the Quality Payment Program (QPP). Within the fee schedule, CMS proposed Medicare payment cuts to the Anesthesia Conversion Factor that will only compound the financial strain that anesthesia groups are already facing. The proposed rule has a 60-day comment period. Final regulations will be issued on or around November 1 and unless otherwise noted, policies will be effective on January 1, 2024.
ASA opposes these additional Medicare payment cuts included in the CY 2024 PFS proposed rule. The proposed rule underscores how the Medicare payment system is broken, especially during a time when anesthesia groups are faced with continued inflation pressures. ASA has already launched an initiative to engage legislative stakeholders and regulatory agencies to minimize and reverse these cuts that negatively impact anesthesiologists.
The 2024 proposed anesthesia conversion factor (CF) is $20.4370, representing a decrease of 3.26% from the 2023 anesthesia CF of $21.1249. The 2024 proposed RBRVS CF is $32.7476. This represents a decrease of 3.36% from the 2023 CF of $33.8872. The CFs will affect physician payments in several ways:
2023 CF | Proposed 2024 CF | Percent Change | |
Anesthesia | $21.1249 | $20.4370 | -3.26% |
RBRVS | $33.8872 | $32.7476 | -3.36% |
Actual payment rates are impacted by a range of proposed policy changes related to physician work, practice expense, and malpractice RVUs. CMS estimated these changes in Table 104 in the proposed rule. Impact by practice will vary based on service mix. Specialty impacts ranged from -4% for Interventional Radiology, to +3% for Endocrinology and Family Practice. The table indicates that the impact of policies in the proposed rule will have on anesthesiology and interventional pain management. Note, changes to the CF are not reflected in the impact table.
Specialty |
Allowed Charges (mil) |
Impact of work RVU Changes |
Impact of PE RVU Changes |
Impact of Malpractice |
Combined Impact |
Anesthesiology |
$1,647 |
-2% |
-1% |
0% |
-2% |
Nurse Anesthetist/ Anesthesiologist Assistant |
$1,081 |
-2% |
0% |
0% |
-2% |
Interventional Pain Management |
$849 |
0% |
0% |
0% |
0% |
*Note: Combined Impact may not equal the sum of work, PE and malpractice due to rounding.
Source: Table 104, CY 2024 Proposed PFS, display copy
Starting January 1, 2024, pain medicine physicians will be able to get paid by Medicare for providing percutaneous sacroiliac (SI) joint arthrodesis using an intra-articular implant(s), such as bone allograft material or synthetic devices. A new category I code (2X000- Arthrodesis, sacroiliac joint, percutaneous, with image guidance, including placement of intra-articular implant(s) (eg, bone allograft[s], synthetic device[s]), without placement of transfixation device) was created to replace the current Category III code 0775T. Code 2X000 was surveyed by the AMA/Specialty Society RVS Update Committee (RUC) which recommended a work RVU of 7.86 to CMS. For CY 2024, CMS has proposed a work RVU of 7.86 for CPT code 2X000, which is the same as the RUC recommended value.
The table below reflects CMS’s proposed work RVUs for the new Arthrodesis, sacroiliac joint code.
Code |
Descriptor* |
2024 Proposed wRVU |
2x000 |
Arthrodesis, sacroiliac joint, percutaneous, with image guidance, including placement of intra-articular implant(s) (eg, bone allograft[s], synthetic device[s]), without placement of transfixation device |
7.86 |
In 2021, CMS implemented G2211, a new add-on code for complex patients that could be appended to any office and outpatient Evaluation and Management (E/M) code. CMS assumed G2211 would be a frequently utilized code that would have a significant impact on budget neutrality. G2211 accounted for an estimated $3.3 billion increase in PFS spending and a corresponding 3%cut to the RBRVS CF in 2021. Due to the potential reduction in payments for physicians who do not bill office and outpatient E/M services, Congress delayed the implementation of G2211 until CY 2024. However, since this policy had been finalized in the CY 2021 PFS final rule and was simply delayed by Congress until CY 2024, the policy will go into effect without any further action on January 1, 2024.
For CY 2024, CMS reaffirms that G2211 will go into effect as expected on January 1, 2024. CMS does, however, modify its assumptions of how frequently G2211 will be utilized. Instead of assuming that G2211 will be billed with 90 percent of all office visit claims, CMS now estimates that G2211 will be billed with 38 percent of all office visit claims initially, but estimates that when fully adopted after several years, G2211 will be billed with 54 percent of all office visit claims.
Despite these revised utilization assumptions that CMS is proposing, G2211 continues to drive a significant payment reduction to the PFS overall for CY 2024. Specifically, CMS notes that approximately 90 percent of the negative 2.17 percent budget neutrality adjustment to the CF for CY 2024 is attributable to G2211 with all other proposed valuation changes making up the other 10 percent.
Code |
Descriptor* |
2024 Proposed wRVU |
G2211 |
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) |
0.33 |
Anesthesiologists continue to face financial pressures beyond these reductions. Medicare payments, including physician services, are also subject to across-the-board cuts due to federal budget rules. Last year, Congress passed legislation that defers until 2025 cuts of 4% that were otherwise scheduled to be implemented in 2022. Mandated by the “Pay-As-You-Go Act of 2010,” these cuts were meant to offset increases in the federal deficit. Although this legislation provided a 1.25% update to the conversion factor for CY 2024, this is less than the 2.5% update Congress approved for CY 2023.
ASA is committed to advocating for changes to the broken Medicare payment system and ensure that anesthesiologists and pain medicine physicians are paid fairly. ASA has supported an inflation adjustment to Medicare payments to allow for the compensation of our physicians and other clinicians to match rising cost of living across the country. Legislation—H.R. 2474, the Strengthening Medicare for Patients and Providers Act—is now introduced in Congress to achieve this change. ASA has also supported Congress and policymakers re-evaluating the budget neutrality clauses of the PFS that greatly restrict payment and cause continued decreases in CFs. ASA looks forward to advocating our position before Congress and in working with CMS and other government stakeholders on proposed solutions.
Please contact [email protected] with any questions related to the Medicare Physician Fee Schedule.
CMS also released its 2024 Quality Payment Program (QPP) Proposed Rule. The proposed rule provides details on how CMS intends for eligible clinicians and groups to participate in the Merit-based Incentive Payment System (MIPS), Alternative Payment Models and other features of the QPP during the 2024 performance year.
For the 2024 reporting year:
Anesthesiologists will continue to have the opportunity to report the Anesthesiology MIPS Value Pathway in 2024. MIPS Value Pathways, CMS believes, will alleviate some of the reporting burdens that anesthesiologists and other physicians encounter in the MIPS program. For 2024, CMS has proposed adding three quality measures:
CMS is proposed to add the IA_MVP: Practice-Wide Quality Improvement in MIPS Value Pathways to this MVP as well.
For more information on the Quality Payment Program, please contact the ASA Department of Quality and Regulatory Affairs (QRA) at [email protected].
ASA leaders and staff will review the rule and submit comments by the deadline. Unless otherwise noted, finalized provisions will become effective on January 1, 2024.
For more information:
Date of last update: July 13, 2023