Highlights from the 2023 proposed payment rule and its impact on gastroenterology
CMS recently released its proposed physician fee schedule for 2023. While the rule provides benefits for patients, it suggests further cuts to physician pay.
Key takeaways for gastroenterology:
◘ CMS proposes to expand Medicare coverage of colorectal cancer screening tests by reducing the minimum age limitation from 50 years to 45 years beginning in 2023.
◘ Expand the regulatory definition of “CRC screening tests” to include the colonoscopy after a positive stool-based CRC screening test.
◘ No beneficiary co-pays would be required for these tests.
◘ Two new codes have been accepted by the CPT editorial panel for endoscopic bariatric device procedure:
>> 43X21 Esophagogastroduodenoscopy, flexible, transoral; with the deployment of the intragastric bariatric balloon
>> 43X22 Esophagogastroduodenoscopy, flexible, transoral; with the removal of the intragastric bariatric balloon(s)
Medicare payment cuts:
◘ The rule proposes 4% cuts to Medicare physician reimbursement.
◘ The proposed CY 2023 PFS conversion factor (CF) is $33.08, a decrease of over 4% or $1.53 from the CY 2022 CF of $34.61.
Updates to MIPS Program:
◘ Merit-Based Incentive Payment System for quality performance, cost performance, improvement activities, and promoting interoperability remains the same at 30%, 30%, 15%, and 25% respectively.
◘ Physicians are exempted from reporting on interoperability till 2024.
◘ Practices with 15 or lower numbers of eligible clinicians are exempted from reporting on the promoting interoperability category.
◘ Physicians see an increase in the data compliance criteria from 70% to 75% beginning with the 2024 performance period.
Other highlights:
◘ Clinicians furnishing split/shared E & M visits will continue to have a choice of history, physical exam, medical decision making, or more than half of the total practitioner time spent to define the substantive portion, instead of using the total time to determine the substantive portion, until CY 2024.
◘ The AMA CPT Editorial Panel approved revised coding and updated guidelines for Other E/M visits, effective January 1, 2023. The revised coding and documentation framework includes CPT code definition changes.
◘ The proposal allows more time for the collection of data that could support their eventual inclusion as permanent additions to the Medicare telehealth services list.
◘ Telehealth claims will require the appropriate place of service (POS) indicator to be included on the claim, rather than modifier “95,” after 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.
The proposed rule points toward major changes to physician reimbursements. While inflation and the cost of running an independent practice continue to rise it is a wait and watch to see how physicians and industry leaders respond to these changes.
Commenting period on the proposed rule ends September 30, 2022.
References:
CMS Proposes Physician Payment Rule to Expand Access to High-Quality Care (CMS.gov)
Proposed changes to Medicare payment policies (AGA)
Medicare Telehealth Services for 2023 – CMS Proposes Substantial Changes (The National Law Review)
CMS seeks 4.42% physician fee cut in 2023 (Becker’s ASC Review)
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