ISASS Submits Comments on 2023 Medicare Physician Fee Schedule Proposed Rule

On September 6, 2022, ISASS submitted comments to CMS on the 2023 Medicare Physician Fee Schedule Proposed Rule, which was released in July 2022.

ISASS’ comments addressed the following areas in addition to general comments regarding the impact of lower reimbursements on physicians and practices.

• Proposed updates to work and/or practice expense (PE) values for evaluation and management (E/M) services codes, including changes to several E/M code families (eg, hospital, emergency medicine, nursing facility, and home visits).
• Proposed work and PE values for new/revised codes describing decompression for posterior fusion (CPT codes 63052 and 63053) and posterior fusion with minimal decompression (22630, 22632, 22633, and 22634).
• Proposed work and PE values for existing laminotomy (CPT codes 63020, 63030, and 63035).
• Proposed delay (until 2024) of the split (or shared) visits policy finalized in calendar year 2022 for 1 year with a few exceptions. This change would redefine the definition of “substantive portion” as more than half of the total time. Clinicians who furnish split (or shared) visits will continue to have a choice of history, physical examination, or medical decision-making, or more than half of the total practitioner time spent to define the substantive portion, instead of using total time to determine the substantive portion.
• Comment on strategies for improving the Global Surgical Package valuation.
• Proposed changes to maintain certain elements of the various telehealth flexibilities authorized on a temporary basis during the COVID-19 public health emergency (PHE). After 151 days following the end of the PHE, many of the services that had been temporarily allowed, including audio-only services, would end.
• The proposed Maintenance of several temporary PHE telehealth codes as Category 3 telehealth codes through at least 2023 to gather more data for future consideration of eventual permanent status as a Medicare telehealth-allowed services.

CMS will respond to ISASS and other stakeholder comments and input in the Medicare Physician Fee Schedule 2023 Final Rule to be published in November 2022.

To read the ISASS comment letter, please see attached.