NHC comments on the 2024 Physician Fee Schedule

By: Allen Pinn, Coordinator, Policy

On July 13, the Centers for Medicare & Medicaid Services (CMS) released their proposed rule for the 2024 Physician Fee Schedule. Below is a summary of the NHC’s comments submitted September 11, 2023.

Expansion of Medicare Telehealth Services

Under the proposed rule, CMS has made several updates to Medicare telehealth services such as adding health and well-being coaches under the Medicare Telehealth Services List. The NHC believes expanding these services will assist in eliminating barriers to care. Moreover, while the NHC recognizes the role telehealth services can play in expanding health equity, guardrails must also be made a priority. Although telehealth services can be offered as an option of care, it should not be seen as a replacement for in-person care. The NHC applauds CMS for its efforts in expanding access to care.

CMS Takes New Steps to Support Caregivers

For the first time, CMS has proposed provisions that would provide reimbursement for the training of caregivers through Medicare. In the 2024 Physician Fee Schedule proposed rule, CMS has proposed to pay for certain caregiver training services to assist individuals receiving Medicare benefits. Under CMS’ proposed rule, the definition of caregiver would remain broad, encapsulating the millions of individuals who make regular sacrifices in the care of their loved ones, which has often gone underpaid or unpaid. Another significant proposal in the rule involves caregiver training services (CTS) in group settings. Regarding CTS, advocates across the patient community are asking CMS to keep the definition of CTS broad. If the proposed rule is to be implemented, advocates are also asking CMS to educate health care providers on the new coding in order to boost caregiver support. This announcement by CMS symbolizes a recognition of the importance of informal caregivers in the lives of patients living with a chronic disease, disability, or advanced age.

New Coding for Community Health Workers, Care Navigators and Peer Support Specialists

In the proposed rule, community health workers (CHWs), care navigators, and peer support specialists have been considered in coding for the care of Medicare beneficiaries. The NHC supports the inclusion of these individuals in addition to the inclusion of community-based organizations and community care hubs as third-party organizations to contract with Medicare providers to deliver Community Health Integration services. The expansion of coding and inclusion of community-based organizations will only strengthen efforts to build health equity among underserved communities.

Advancing Health Equity

Regarding health equity, the NHC is pleased by the inclusion of social determinants of health (SDOH) risk assessments as a part of Medicare annual wellness visits and/or evaluation/management visits. SDOH play a significant role in a patient’s health, and  assessing SDOH could be used in the creation of individualized care plans. In addition, another provision advancing health equity in the proposed rule is the advancement of Community Health Integration (CHI) services, which play an important role in mitigating population health. Lastly, the proposed rule also calls for the inclusion of principal illnesses navigator services, which will aid individuals living with complex needs.


For a more in-depth look at the NHC’s regarding the 2024 Physician Fee Schedule, click here . If you have any questions about the NHC’s policy priorities or 2023 policy matrix, please contact Eric Gascho, Senior Vice President, Policy and Government Affairs.