The internet is ringing with the news of the CMS Updates Final rule for the 2023 Medicare Physician Fee Schedule. The finalized 2023 Medicare Physician Fee Schedule was announced by the Centers for Medicare & Medicaid Services (CMS) on November 1 2022. The 2023 MPFS features a decrease in the fee schedule conversion factor from $34.6062 to $33.0607, reflecting in part the expiration of the temporary 3% supplementary increase in fee schedule payments for CY 2022, among other significant modifications outlined by CMS.
Additionally, the 2023 MPFS includes adjustments to telehealth flexibilities that correspond to provisions of the 2022 Consolidated Appropriations Act, such as the extending of several telehealth flexibilities for a period of 151 days after the COVID-19 Public Health Emergency has ended (currently set to expire January 11, 2023, but subject to further extension). In addition to these revisions, the 2023 MPFS contains information on revised coding, work RVUs, and practice expense RVUs for E/M) and other services, as well as revisions to the Medicare Shared Savings Program and Quality Payment Program.
Principles of PFS
- On November 1, 2022, the Physician Fee Schedule final regulations were published, and they will take effect on January 1, 2023.
- Depending on the type of service and the location of the treatment, the PFS informs payers (insurance companies and patients) of the appropriate payment to be made for physicians’ services. As a result, adjustments to the PFS over time may cause a physician’s final payment for the same service to change.
- The conversion factor is one of the key elements of PFS. This is determined by multiplying the actual fees paid for a service or treatment by the Relative Value Unit (RVU). It seems sense that the physician’s share of the payment would be higher the higher the conversion factor.
- These and other acts that affect physicians and other healthcare workers will be closely watched by us. If you have any inquiries regarding the Final Rule, please get in contact with your DLA Piper relationship partner, the authors of this notice, or any other member of our healthcare sector group.
Effects of the PFS in 2023 on providers
- Many medical associations have begun to express their dissatisfaction with the final guidelines for the 2023 Physician Fee Schedule. These organizations contend that the reduction in the conversion factor will increase financial pressure on doctors, put medical professionals against one another, and heighten competitiveness.
- Additionally, these groups note that this loss would come on top of the 4% PAYGO sequestration and could result in a further decline in revenue in group practices when federal spending exceeds a predetermined amount.
- Physicians and other healthcare professionals are concerned that this move could cause financial instability, and limit their ability to give the best care possible to those in need. We must wait to see how this will actually impact the financial picture.
Patient effects of the 2023 PFS
- The Physician Fee Schedule final rules for 2023 include a lot of advantages for patients.
- The impact on behavioral health is the main issue to be covered. Because the treatments might not be reimbursed and the out-of-pocket costs might be high, a sizable segment of the population is reluctant to seek help from behavioral health specialists.
- However, many behavioral difficulties today emerge as physical concerns, and unless the latter are resolved, the former won’t be either.
- The 2023 PFS rules, which contain solutions for behavioral health, mental health, and physical health, may help provide patients with holistic healthcare services.
- When it comes to insurance inclusions, the term “pain care” has always been delicate ground to walk on. Access to pain therapy will now be aided by higher payment rates for opioid-based treatments.
- Patients can look forward to CMS continuing to pay for extended telehealth services even after the Public Health Emergency has expired.
A glance at other factors
1. Reduction in the conversion factor and payment
The conversion factor was reduced by $1.55 in the 2023 PFS, resulting in a CY 2023 conversion factor of $33.06. This conversion factor also takes into account the expiration of the Protecting Medicare and American Farmers from Sequester Cuts Act’s temporary, offsetting 3% increase in payments for CY 2022 as well as the statutorily required budget neutrality adjustment to take into account changes in payment rates.
2. Changes in RUC value for ophthalmic operations
The RUC-recommended practice expense and work values for the orthoptics CPT code 92065 as well as the RUC-recommended practice expense and work values for the anterior segment imaging CPT code 99287 were both accepted by the CMS.
3. Cataract surgery performed in an office
The CMS said in its proposed rule that it had received requests to establish non-facility values for the vitrectomy and cataract surgery codes because it had been indicated that these procedures may be carried out in an office setting outside of a facility in a safe and efficient manner. Before moving forward with a value, the AOA urged CMS to assess outcomes information on the effectiveness of surgeries in this situation.
The CMS decided to further analyze these services before establishing any values after expressing reservations about them in the final rule.
4. Techniques for raising the value of surgical packages globally
The AOA urged a continued reliance on the RUC process in the CMS’ proposed rule when determining how many pre- and post-surgery visits should be included in a surgical package. The AOA stated that CMS should keep using the data gathered from the RUC Relativity Assessment Workgroup’s work, which identifies services with global periods that may be undervalued. Furthermore, the AOA noted that such efforts would be better spent evaluating particular codes of concern as opposed to making generalizations about the global surgery packages as a whole.
5. Medicare reimbursement for telehealth services
The CMS indicated that while CPT codes 92012 and 92014 would remain on the Medicare Telehealth Services list through the end of 2023, CPT codes 92002 and 92004 will be removed after 151 days following the end of the public health emergency (PHE) declaration.
6. MIPS registry active participation
The CMS and the AOA agreed that it was necessary to postpone the requirement that MIPS-eligible clinicians spend one performance period at the Preproduction and Validation level of active engagement for each measure before moving on to the Validated Data Production level in the following performance period for which they report a specific measure. The CMS will postpone this modification until 2024.
Conclusion
We at Medisys Data Solutions, the Best medical billing and coding company in the US, will be closely monitoring these and other activities that have an effect on doctors and other healthcare professionals.
