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Updated Coding in CMS’s Proposed Medicare Physician Fee Schedule for 2024 Advances Health Equity


A new piece of the health equity puzzle just arrived: in 2024, Medicare physicians will receive compensation for some previously uncovered services that support health equity goals. And it’s no surprise that health equity plays a key role in what services the Centers for Medicare and Medicaid Services (CMS) will reimburse in 2024. This year, CMS required Realizing Equity, Access and Community Health (REACH) Accountable Care Organizations (ACOs) to develop comprehensive health equity plans, though no penalties will incur until 2024 for the plans that do not work in practice. 

The proposed Medicare Physician Fee Schedule for 2024 CMS recently shared gives details – think reimbursement codes and specific services – for offerings that advance health equity. As such, a complete understanding of these proposed codes will support risk-bearing organizations as they envision what health equity will look like next year in terms of their finances. Having a solid plan in place matters financially for REACH ACOs especially, since requirements dictate the ACOs demonstrate the efficacy of their health equity plans in 2024. 

In particular, CMS’s announcement covers five key proposed areas for reimbursement that will impact risk-bearing organizations financially and affect the health outcomes of the people they serve. The proposed 2024 fee schedule aims to empower ACOs to better deliver on health equity goals. Let’s take a look at five components eligible for reimbursement outlined in the Medicare Physician Fee Schedule for 2024.


Social Determinant of Health Assessments

First, the proposed fee schedule for 2024 includes coding to reimburse for social determinants of health (SDOH) assessments, marking an important step for coverage of SDOH factors. Understanding the complexities of issues facing patients is imperative for developing targeted interventions that address health disparities. For example, if a patient lives in a food desert or does not have access to reliable transportation to get to medical appointments, those social determinants can greatly impact the patient’s overall health. As such, the inclusion of coding for SDOH assessments in the 2024 Medicare Physician Fee Schedule is a significant stride towards realizing health equity goals. 

Coding for SDOH assessments means ACOs can now have additional incentive – receiving reimbursement – for systematically identifying and documenting the social factors affecting their patients’ health, including socioeconomic status, education, employment, and social support systems. Armed with this valuable data, ACOs can more effectively tailor interventions to meet the unique needs of their patient populations. By proactively addressing SDOH factors, ACOs can mitigate barriers to care and foster a more equitable healthcare environment.


Community Health Integration Services 

In addition to SDOH assessments, CMS detailed plans to reimburse for offerings that connect at-risk populations with community services. This will include separate coding and payment for community health integration services. The approach aims to address unmet social determinants of health needs that can hinder a practitioner’s ability to effectively diagnose and treat patients.

Of note, the community health integration services CMS will create codes for encompass: person-centered planning, promotion of patient self-advocacy, facilitating access to community-based resources, and health system coordination. Such action points to CMS’s support of bridging the gap between healthcare and social services to compensate for social determinants of health risks that impact individual’s health. 

A key aspect of these proposed changes in codes: the inclusion of care involving community health workers. These individuals serve as vital links between underserved communities and critical healthcare and social services. By leveraging the expertise of community health workers, CMS could help extend equitable access to care, particularly for vulnerable populations within the Medicare community.

Of course the goal of integrating community health workers into the healthcare system aims to improve health outcomes for the Medicare population. These initiatives not only address immediate healthcare needs but also recognize the significance of social determinants of health.


Caregiver Training

Further, the proposed Medicare Physician Fee Schedule for 2024 addresses coding for caregiver training. A significant obstacle to achieving health equity is ensuring patients follow through on treatment plans and adhere to prescribed medications. However, caregivers can play a significant role in patients’ ability to meet doctor directives. For example, caregivers can help a dementia patient remember to take medicine or remind a diabetic to track insulin use. 

In particular, the 2024 proposed Fee Schedule acknowledges the importance of caregivers and allocates reimbursement for their training. This initiative recognizes that family members and informal caregivers play a crucial role in supporting patients, especially those with chronic conditions or limited mobility. By CMS covering caregiver training, risk bearing organizations can enhance the support system available for patients, thereby improving treatment compliance and health outcomes. For underserved communities with limited access to healthcare facilities, well-trained caregivers can prove instrumental in ensuring patients receive the care they need.


Behavioral Health Therapists

Additionally, the proposed fee schedule in 2024 will offer coding to reimburse behavioral health therapists. Mental health plays a vital role in overall well-being, and its impact on health equity cannot be overlooked. The CMS decision to approve enrollment of behavioral health therapists for Medicare reimbursement is a game-changer. This move facilitates increased access to mental health services for Medicare beneficiaries, including those from disadvantaged backgrounds. 

By integrating behavioral health services into primary care settings, ACOs can offer more comprehensive and patient-centered care. For underserved communities, this represents an opportunity to receive much-needed mental health support, reducing disparities in mental healthcare access and outcomes. Specifically, addiction counselors, mental health counselors, and family and marriage therapists can receive reimbursement under the new Medicare coding.


Primary Care and MSSP

Quality primary care makes a significant impact on advancing health equity. With this in mind, the proposed CMS payment schedule offers new coding and increased payment for primary care services. Augmented compensation for these key services can help physicians offer the care patients need. 

Further, the additional coding can promote preventive care and early intervention by providing more support to primary care providers who play a crucial role in disease prevention and health promotion. This approach can lead to better health outcomes for patients in underserved communities, potentially reducing the burden on emergency care and hospitalizations.

In addition, the proposed changes can advance health equity through the Medicare Shared Savings Program. The adjustments aim to promote patients receiving primary care from physician assistants, clinical nurse specialists, and nurse practitioners. As well, the changes can potentially incentivize more ACOs to participate in the program.


Implications for Health Equity

In total, the proposed updates promote more inclusive, patient-centered, and accessible healthcare. Offering increased coding and correlated reimbursements can help to bridge the gap towards health equity. 

Now it is up to risk-bearing organizations to take advantage of the proposed coding and related reimbursements. Such action can address longstanding disparities that have hindered access to healthcare for vulnerable populations. Doing so successfully should positively impact both their patient health outcomes and their bottom line.


Role of Technology in Health Equity

Here’s where technology can support risk-bearing organizations in capitalizing on the proposed Medicare coding: offering physicians up-to-date, targeted intervention recommendations for their individual patients based on the unique social determinant risks of each. Such solutions in conjunction with the new coding can empower physicians to advance health equity for all their patients. 

Now it’s up to risk-bearing organizations to put a plan in place to flag what social determinants face their patient populations to capitalize on the proposed coding and reimbursement come 2024. 

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