September 11, 2023: MGMA provides comprehensive comments on 2024 Medicare Physician Fee Schedule proposals

September 11, 2023 

The Honorable Chiquita Brooks-LaSure
Administrator
Centers for Medicare & Medicaid Services
U.S. Department of Health and Human Services
200 Independence Avenue, SW
Washington, DC 20201

Re: Medicare and Medicaid Programs; CY 2024 Payment Policies Under the Physician Fee Schedule and Other Changes to Part B Payment and Coverage Policies; Medicare Shared Savings Program Requirements; Medicare Advantage; Medicare and Medicaid Provider and Supplier Enrollment Policies; and Basic Health Program [CMS - 1784 - P]

Dear Administrator Brooks-LaSure:

The Medical Group Management Association (MGMA) is pleased to submit the following comments in response to the calendar year (CY) 2024 Physician Fee Schedule (PFS) and Quality Payment Program (QPP) proposed rule, published in the Federal Register on Aug. 7, 2023.

With a membership of more than 60,000 medical practice administrators, executives, and leaders, MGMA represents more than 15,000 medical groups comprising more than 350,000 physicians. These groups range from small independent practices in remote and other underserved areas to large regional and national health systems that cover the full spectrum of physician specialties.

Key Recommendations
MGMA appreciates the Centers for Medicare & Medicaid Services’ (CMS) leadership in improving Medicare and respectfully offers the following comments in response to the CY 2024 PFS proposed rule. In summary, we encourage the agency to:

• Urge Congress to provide a positive update to the Medicare conversion factor in CY 2024 and all future years. MGMA is deeply concerned with the estimated reduction to the CY 2024 conversion factor and its potential impact on medical group practices. The cuts stemming from the 3.36% decrease to the CY 2024 conversion factor paired with the current inflationary environment are simply unsustainable. In an MGMA poll conducted in August 2023, 95% of medical practices reported that the projected reduction to 2024 Medicare payment would negatively impact their ability to deliver timely, high-quality care to patients.1
• Provide further clarity and guidance surrounding the utilization of HCPCS code G2211. For CMS to properly implement this code, the agency must further refine its utilization assumption, clarify ongoing questions surrounding utilization of the code, and share robust guidance with the provider community. 

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