CMS Issues CY 2023 Proposed Rules for Medicare Physician Fee Schedule (MPFS)
On July 7, 2022, the Centers for Medicare and Medicaid Services (CMS) issued the proposed rule for the Medicare Physician Fee Schedule (MFPS). These proposed rules cover physician services furnished to beneficiaries on or after January 1, 2023. Highlights are described below:
- CMS proposed Conversion Factor (CF) of $33.0775, which includes omission of the 3.00 percent increase signed into law at end of 2021 and a budget neutrality factor of -1.55 percent.
- Based on the proposed changes for the RVUs, CMS estimates combined payment impact for cardiac surgery is -1 percent; for interventional radiology is -4 percent; and for vascular surgery is -3 percent.
- CMS proposed to create a specialty-level risk index for the calculation of MP RUVs, which is reflective of patterns seen in most current premium data. In addition, a phase-in reduction in the MP RVUs over 3 years based on an impact threshold is proposed.
- Proposals for the geographic practice cost indices (GPCIs) include continuation of work floor GPCI at 1.000; continuation of Alaska work floor GPCI at 1.500 and frontier states at 1.000; and refining several of the California localities, which would reduce 32 localities to 29.
- The Medicare Economic Index (MEI) cost share weights have been proposed to be rebased and revised, including a new methodology for estimating base year expenses which rely on publicly available data from the U.S. Census Bureau; delaying the adjustments to the PE pools; and the recalibration of the relativity adjustment.
- CMS proposed clarifications/revisions for evaluation and management (E/M) to include valuation of prolonged E/M services; “Other E/M” services; split or shared visits being fully integrated in CY 2024; revision of the definitions for “initial” and “subsequent” for inpatient E/M visits; continuation of the “8 to 24 hour rule”; payment for teaching physician services; and telehealth and communication technology-based services.
- CMS is seeking feedback on whether additional time is needed beyond the 151-day period after the end of the public health emergency (PHE) before returning to the standard application of direct supervision for physicians; and whether direct supervision in the office setting should be permanently allowed by real time audio/video for a subset of services.
The complete MPFS proposed rule summary can be found on the GORE Coding Resource Center website under “Education – CMS Rules Updates”: https://gore.rccsclients.com/education/rules-updates/.
