CMS Releases Physician Fee Schedule Final Rule for CY 2024

The Centers for Medicare and Medicaid Services (CMS) on Thursday released the calendar year (CY) 2024 Medicare Physician Fee Schedule (PFS) final rule, which is scheduled for publication in the Federal Register on Nov. 16. The agency also released an accompanying fact sheet.

The rule finalizes several CPT codes related to therapeutic apheresis. In response to the proposed rule, released in September, AABB, America’s Blood Centers and the American Red Cross wrote CMS administrator Chiquita Brooks-LaSure to request that the agency establish a new clinical labor code for a therapeutic apheresis nurse with a labor rate reflecting the skills and experience required in that position.

The organizations also asked CMS to increase the payment rates assigned to therapeutic apheresis CPT codes to reflect the total cost of these procedures. Specifically, the relevant CPT codes are 36514 (Therapeutic apheresis; for plasma pheresis), 36516 (Therapeutic apheresis; with extracorporeal immunoadsorption, selective adsorption, or selective filtration and plasma reinfusion) and 36522 (Photopheresis, extracorporeal).

In response to feedback from the blood community, CMS acknowledged the potential disparity in clinical labor codes for therapeutic apheresis services and committed to revisiting these codes in future rulemaking. CMS also recognized that the current general RN/LPN labor category may not adequately represent an apheresis nurse specialist. While there is currently no specific apheresis nurse category listed in the PFS, the agency wrote, there may be existing nurse categories, such as oncology nurses, that could serve as suitable alternatives.

For CY 2024, CMS finalized CPT codes 36514, 36516 and 36522 as potentially misvalued.