CMS Releases 2023 Medicare Physician Fee Schedule Final Rule
On November 1, 2022, the CMS released the calendar year (CY) 2023 Medicare Physician Payment Schedule and Quality Payment Program final rule that impacts payments for physicians and other health care practitioners. CMS had issued a proposed rule in July, which ISASS responded to with a robust set of comments.
Below are some of the main policies from the final rule.
- CMS finalized the CY 2023 Medicare conversion factor ss $33.06, a decrease of $1.55 (or 4.5 percent) from the 2022 conversion factor of $34.61. The decrease is largely a result of an expiring 3% increase funded by Congress through 2022. The additional approximate 1.6% decrease is the result of budget neutrality requirements that stem from the revised evaluation and management (E/M) changes. ISASS and other organizations continue to strongly advocate that Congress avert this payment cut, as well as implement an inflationary update for physicians, extend the 5% advanced Alternative Payment Model (APM) incentive, prevent the steep increase to the participation requirements for APMs, and waive the 4% PAYGO sequester.
- CMS has finalized the Medicare Economic Index (MEI) weights for the different cost components of the MEI. The current MEI weights are based primarily on results from the American Medical Association’s (AMA’s) Physician Practice Information (PPI) survey based on 2006 data. CMS used data from the Census Bureau’s Service Annual Survey (SAS) as the primary source for the new weights and supplemented the data with other sources, which led to substantial changes in the weights for many of the key components of physician practice expense. CMS will not implement the MEI changes in 2023, referencing the need for continued public comment due to the significant impact to physician payments. CMS also stated that they will be interested in comparing the results of the AMA practice expense data collection effort to the data used in their new MEI calculation.
- CMS finalized its proposal to extend telehealth coverage for an additional 5 months beyond the end of the public health emergency.
- CMS agreed to maintain the same payment rates for office visits provided in-person or via telehealth through the end of 2023.
- CMS adopted the revised Current Procedural Terminology guidelines and codes, and the AMA/Specialty Society RVS Update Committee (RUC) recommended relative values for additional E/M visit code families, including hospital, emergency department, home, and nursing facility visits. These changes allow time or medical decision-making to be used to select the E/M visit level.
- CMS finalized creation of Medicare-specific coding for payment of Other E/M prolonged services, similar to what CMS adopted in CY 2021 for payment of Office/Outpatient prolonged services. These services will be reported with three separate Medicare-specific G codes.
- CMS finalized a 1-year delay of its policy requiring a physician to see the patient for more than half of the total time of a split or shared E/M visit in order to bill for the service. CMS will continue to allow physicians and qualified health care professionals to use history, physical examination, medical decision-making, or more than half of the total time spent with a patient to determine the substantive portion of the split/shared visit in 2023.
- CMS finalized new Healthcare Common Procedural Coding System codes, G3002 and G3003, and valuation for chronic pain management and treatment services (CPM) for CY 2023 and provided some additional flexibilities, such as the ability to report CPM and other visits on the same date and to report subsequent CPM services as many times as needed in a month.
To read ISASS comments on the proposed changes, see attached.