CY24 CMS Proposed Rules Summary for RHCs
Provides MHC and MFT Coverage Details, Adds Remote Patient Monitoring and other services to G0511, Among Other Key Provisions for RHCs
Sarah Hohman, Director of Government Affairs
On July 13th, the Centers for Medicare and Medicaid Services (CMS) issued the CY 2024 Medicare Physician Fee Schedule (MPFS) Proposed Rule, as well as the 2024 Medicare Hospital Outpatient Prospective System (HOPPS) Proposed Rule. This year’s 2,033 page and 963 page rules, respectively, contain several Rural Health Clinic (RHC) specific policy proposals, as well as other provisions with implications for the RHC community.
“This year’s rulemaking cycle has the most RHC-relevant provisions of any year since I began working with rural health clinics,” said Nathan Baugh, Executive Director of NARHC. “The marriage and family therapist and mental health counselor proposals were in line with what we were expecting, and I am excited to see RHCs begin utilizing those provider types. The addition of remote patient/therapeutic monitoring for RHCs is also great and long overdue but we have increasing concerns that folding most of care management into a single code (G0511) is not viable.”
If these policies are finalized by CMS this November, they would go into effect January 1, 2024, unless otherwise specified. In order to provide the complete details on RHC-relevant provisions and NARHC’s perspectives on this year’s proposals, the larger topics have been broken down into separate articles, all linked below!
The National Association of Rural Health Clinics (NARHC) will be submitting comments on all RHC-provisions, which will be reviewed by the NARHC Policy Committee, to CMS in mid-September.
We encourage you to join our Washington, D.C. team for a webinar on August 30th, 2023 where we will discuss both proposed rules and hear your feedback about implementation of these various policy proposals. Please register for the webinar here.
Please review the linked articles on this year’s major proposed topics:
New Billable RHC Providers: Marriage and Family Therapists & Mental Health Counselors
Intensive Outpatient Services Treatment Category
- Revision to G0511 Payment Methodology
- Beneficiary Consent Clarification
- Definition of Nurse Practitioner
- Telehealth Regulation
What was NOT Proposed
While covering what is included in the proposed rules is important, it is also important to identify items that we had thought or hoped would be included that were not addressed by CMS.
For instance, NARHC was hopeful that CMS would utilize this rulemaking opportunity to further expand upon preventive care eligible for adequate reimbursement in the RHC setting by amending the definition of an RHC medical visit to allow for Annual Wellness Visits (other than IPPEs) to be eligible for same day billing. Finally, we were hopeful that CMS would further elaborate on the interim policy regarding the RHC “urbanized area” issue, however there was no mention of this in the proposed rules.
NARHC appreciates the various RHC-provisions included in this year’s proposed rule and we look forward to engaging with CMS on a variety of modifications to these policies to ensure that safety-net providers have access to the same opportunities as fee-for-service providers.
Please contact Sarah Hohman, NARHC Director of Government Affairs at Sarah.Hohman@narhc.org with any questions or other feedback, and don’t forget to register for NARHC’s August 30th webinar on these proposed rules here.
