2023 MEDICARE PHYSICIAN FEE SCHEDULE (MPFS) PROPOSED RULE RELEASED
Includes 2023 Quality Payment Program Proposals
Proposed 2023 Conversion Factor: $33.0775
This afternoon, CMS released the CY 2023 MPFS Proposed Rule. CMS also released a press release, a physician fee schedule fact sheet, and a QPP fact sheet. ASCRS will be submitting comments.
2023 MPFS Conversion Factor
The CY 2023 proposed MPFS conversion factor is $33.0775, a decrease of approximately 4.5% ($1.53) from the CY 2022 MPFS conversion factor of $34.6062. The CY 2023 proposed MPFS conversion factor reflects a budget neutrality adjustment of 1.55%, the expiration of the 3.00% payment increase provided for CY 2022 by the Protecting Medicare and American Farmers from Sequester Cuts Act, and the 0.00% update adjustment factor as established in MACRA.
According to the CMS estimated impact on total allowed charges by specialty, ophthalmology is impacted by 0%. However, it appears that the 3.00% reduction is not included in the impact table. For CY 2023, the proposed Medicare payment rate for 66984 is $530.98, a decrease of $13.81 from the CY 2022 Medicare payment of $544.70.
We will continue to advocate with the medical and surgical community to prevent these Medicare physician payment cuts.
Medicare Economic Index (MEI) for CY 2023
CMS is proposing to rebase and revise the MEI cost share weights for CY 2023. MEI measures the input price pressures of providing physician services. CMS is proposing a new methodology for estimating base year expenses that relies on publicly available data from the U.S. Census Bureau NAICS 6211 Offices of Physicians.
Using the new MEI cost weights to set PFS rates would not change overall spending on PFS services but would likely result in significant changes to payments among PFS services. CMS is proposing not to use the proposed updated MEI cost share weights to set PFS payment rates for CY 2023, but rather potentially using the updated MEI cost share weights to calibrate payment rates and update the GPCI under the PFS in the future.
Evaluation and Management (E/M) Visits
CMS is proposing to adopt changes to several E/M code families, including hospital, emergency medicine, nursing facility, and home visits, as recommended by the CPT Editorial Panel and AMA/Specialty Society RVS Update Committee (RUC). Due to statutory budget neutrality requirements, these proposed changes are estimated to require an additional reduction of 1.5% to the CY 2023 MPFS conversion factor.
10- and 90-day Global Surgical Codes
Unfortunately, this proposed rule does not include increases to the value of E/M post-operative services in 10- and 90-day global surgical codes. However, CMS is soliciting public comment on strategies for improving global surgical package valuation and paying more accurately for the global surgical packages, and ASCRS plans to comment. We will continue to work with the surgical community advocating that Congress direct the CMS to adjust the values of the E/M post-operative visits included in 10-day and 90-day global surgical codes to reflect the updated office/outpatient E/M code payment increases that were implemented on January 1, 2021.
Medicare Telehealth Services
For CY 2023, CMS is proposing to allow certain services added to the Medicare telehealth list to remain on the list to the end of December 31, 2023, on a Category III basis, which would allow more time for collection of data that could support their eventual inclusion as permanent additions to the Medicare telehealth services list. CMS is also proposing to extend the duration of time that services are temporarily included on the telehealth services list during the Public Health Emergency (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. These policies extend certain PHE flexibilities, such as allowing telehealth services to be provided in any geographic area and in any originating site setting (including the beneficiary’s home), allowing certain services to be furnished via audio-only telecommunications systems, and allowing certain mid-level providers to furnish telehealth services.
Quality Payment Program
MIPS Value Pathways (MVPs)
CMS is proposing 5 new MVPs and revising 6 previously established MVPs that would be available beginning with the 2023 performance year, which does not include ophthalmology. As a reminder, the addition of MVPs is part of a greater effort at CMS to sunset traditional MIPS after the end of the 2027 performance period/2029 payment year. CMS did not propose the timeframe in which MVP reporting would no longer be voluntary and said any proposal to sunset traditional MIPS will be made in future rulemaking. ASCRS will be providing comments explaining that the traditional MIPS pathway should not be terminated.
Performance Threshold Proposals
CMS is proposing that the performance threshold continue to be the mean final score from the 2017 performance year/2019 MIPS payment year, which would result in a performance threshold of 75 points. The 2022 performance year/2024 payment year was the final year for an additional performance threshold/additional MIPS adjustment for exceptional performance.
Performance Category Weights
For the 2023 performance year/2025 payment year, CMS is proposing the following performance category weights:
- 30% for the Quality performance category.
- 30% for the Cost performance category.
- 15% for the Improvement Activities performance category.
- 25% for the Promoting Interoperability performance category.
Additional Details to Come
ASCRS is reviewing the 2,066-page proposal and additional information will be detailed in upcoming editions of Washington Watch Weekly.