Highlights from the Proposed Physician Fee Schedule for 2023 – Part 1

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The Centers for Medicare and Medicaid Services (CMS) released the 2023 Proposed Physician Fee Schedule in early July, with the comment period being open until Tuesday, Sept. 6, 2022. Physicians and practice leaders are encouraged to comment as CMS will address each comment in the Final Rule, expected in November or December this year.

Some of the highlights where comments should be considered include:

Conversion Factor (CF): The proposed CF is $33.0775, representing a decrease of $1.53 or almost a 4.42 percent decrease from the 2022 reimbursement year. The adjustment was made in order to reach budget neutrality (as required by mandate) and the expiration of the 3.0 percent increase from 2022 required by the congressional action of Protecting Medicare and American Farmers from Sequester Cuts Act. 

In addition, as required every three years, CMS has reviewed and updated the Geographic Practice Cost Indices (GPCI). CMS plans to implement half of the GPCI adjustments in 2023 and the remaining half in 2024. Medical practices are also facing an additional potential PAYGO 4.0 percent decrease to reimbursement triggered by legislation from the American Rescue Plan (ARPA) in March 2021.  Only congressional action will stop PAYGO.

What does this mean for specialty practices? The MPFS will vary depending on the specialty. The InfoDive® team looked at data from the specialty practices, along with CPT classifications, to create an impact scenario based on the Proposed Rule. If the Proposed Rule stays as proposed and there is no congressional action, some examples of the decrease include: neurology -5.8 percent; gastroenterology -5.2 percent; rheumatology -4.5 percent, oncology -3.7 percent and vision -2.9 percent. In addition, the team looked at CPT classification to see where the impact will be seen. Path and Lab codes will see the greatest decrease by -5.4 percent, but Medicine (typically those infusion and injections codes) will see a 5.0 percent decrease.

Understanding these numbers will help practices budget for the next year, if the Proposed Rule is accepted as the final ruling. Practices are already dealing with the 2.0 percent sequestration impact which started July 1, 2022, so commenting on the impact to your practice and your patients is essential.

Evaluation and Management (E/M) Changes: There are significant proposed changes to the Evaluation and Management (E/M) section of the CPT book. Prolonged services are being revised and there are 25 codes that will be deleted. These changes build on the revisions to office/outpatient E/M codes in 2020 that emphasized medical decision-making and/or time to reduce the provider’s documentation burden. These E/M changes will affect hospital inpatients, observation care visits, consultations, emergency room visits, nursing facility services along with home, rest home, and domiciliary E/M codes. If practices are looking for assistance in reviewing these potential changes, please contact the team at InfoDiveSupport@intrinsiq.comPractices that bill consultation codes should review the two consultation codes (99241 and 99251) which are proposed to be deleted, especially as CMS will require that consult requests come from other healthcare professionals.

Practices are also encouraged to review the proposed changes for Split/Shared E/M if this is something that a practice bills, as CMS is proposing to delay implementation of the definition for a “substantial portion” of the visit.

The InfoDive team has been supporting practices with powerful business intelligence that can help with approaches to coding, productivity, revenue collection, and more. The team presents informational webinars monthly to help practices understand how their data can help their financial health, especially during the everchanging reimbursement landscape. Their most recent webinar on the 2023 Medicare PFS Proposed Rule can be found at: https://globalmeetwebinar.webcasts.com/starthere.jsp?ei=1561110&tp_key=34dd6066c0.

For answers to your questions, contact InfoDiveSupport@intrinsiq.com.