by Amanda Ballif
Jul 28th, 2022
The Centers for Medicare and Medicaid Services (CMS) is soliciting public comments on proposed policy changes for Medicare payments under the Physician Fee Schedule (PFS) and other Medicare Part B issues which becomes effective January 1, 2023. The Calendar Year (CY) 2023 PFS proposed rule is one of several proposed rules aimed at increasing equity in health care by means of better accessibility, quality, affordability, and innovation. The comment period closes on September 6, 2022. Click HERE to access the comment area (blue button, top left).
CMS is looking for specific comments and information in the following areas: 1) global surgical packages valuation under the PFS; and 2) ways to identify and improve access to high value and potential underutilized services by Medicare beneficiaries
Tip: Watch for another article in August about major proposed changes.
CY 2023 PFS Rate Setting and Conversion Factor
From CMS: “We are proposing a series of standard technical proposals involving practice expense, including the implementation of the second year of the clinical labor pricing update. We have also included a comment solicitation seeking public input as we develop a more consistent, predictable approach to incorporating new data in setting PFS rates. We hope to implement changes that will promote transparency and predictability in payment amounts. Per statutory requirements, we are also updating the data that we use to develop the geographic practice cost indices (GPCIs) and malpractice RVUs.”
To ensure the payment rates don’t result in changes to Medicare spending, CMS says “the required statutory update to the conversion factor for CY 2023 of 0%, and the expiration of the 3% increase in PFS payments for CY 2022, the proposed CY 2023 PFS conversion factor is $33.08, a decrease of $1.53 to the CY 2022 PFS conversion factor of $34.61.”
Updated Medicare Economic Index (MEI) for CY 2023
Medicare is proposing to rebase and revise the MEI cost share weights for next year. It is soliciting comments about the proposal that “measures the input price pressures of providing physician services.”
Along with that, they are proposing a new method for estimating expenses that rely on public data from the U.S. Census Bureau NAICS 6211 Offices of Physicians.
Evaluation and Management (E/M) Visits
The AMA CPT Editorial Panel approved and is looking to adopt changes in coding and documentation for Other E/M visits effective January 1, 2023.
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New descriptor times (where relevant).
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Revised interpretive guidelines for levels of medical decision making.
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Choice of medical decision making or time to select code level (except for a few families like emergency department visits and cognitive impairment assessment, which are not timed services).
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Eliminated use of history and exam to determine code level (instead there would be a requirement for a medically appropriate history and exam).”
ALERT: This is a BIG change which will affect many organizations. Watch for further articles, announcements, and webinars from innoviHealth.
Split (or Shared) E/M Visits
For CY 2023, CMS is proposing to delay the split (or shared) visits policy they finalized in CY 2022, for one year with exceptions.
Telehealth Services
CMS asserts: “We are proposing to extend the duration of time that services are temporarily included on the telehealth services list during the PHE, but are not included on a Category I, II, or III basis for a period of 151 days following the end of the PHE, in alignment with the Consolidated Appropriations Act, 2022 (CAA, 2022)...We are proposing that telehealth claims will require the appropriate place of service (POS) indicator to be included on the claim, rather than modifier “95,” after a period of 151 days following the end of the PHE and that modifier “93” will be available to indicate that a Medicare telehealth service was furnished via audio-only technology, where appropriate.”
Tip: See one of innoviHealth’s specialty-specific Reimbursement Guides for more information about reporting telehealth services. You can also review other articles on our Telehealth topics page by clicking HERE.
Other Services That May See Changes
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Behavioral Health Services
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Cost of surgery across the globe
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Chronic Pain Management Services
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Opioid Treatment Programs (OTPs)
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Audiology Services
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Dental and Oral Health Services
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Skin Substitutes
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Colorectal Cancer Screening
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Requiring Manufacturers of Certain Single-Dose Container or Single-Use Package Drugs to Provide Refunds with Respect to Discarded Amounts
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Preventative Vaccine Administration Services
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Clinical Laboratory Fee Schedule (CLFS)
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Medicare Ground Ambulance Data Collection System
Rural Health Clinics (RHCs) and Federally Qualified Health Centers (FQHCs)
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Chronic Pain Management and Behavioral Health Services
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Telehealth Services
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Conforming Technical Changes to the In-Person Requirements for Mental Health Visits
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Specified Provider-Based RHC Payment Limit Per-Visit
Resources:
Fact sheets:
CMS Blog: Proposed Behavioral Health Changes
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