7 August, 2023 16:58

August 7, 2023
Dear RHC Community,

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 available on NARHC.org.
The relevant provisions include:

  • New Billable RHC Providers: Marriage and Family Therapists & Mental Health Counselors
  • Intensive Outpatient Program Treatment Category
  • Remote Patient Monitoring, Remote Therapeutic Monitoring, Community Health Integration, and Principal Illness Navigation Services Billable Under G0511
    • Revision to G0511 Payment Methodology
    • Beneficiary Consent Clarification
  • Other Proposals
    • Definition of Nurse Practitioner Change
    • Telehealth Regulation

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.

With any questions, please contact Sarah Hohman at Sarah.Hohman@narhc.org.

Sincerely,
National Association of Rural Health Clinics

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