Coding Corner – Medicare Physician Fee Schedule: CY23 Proposed Rule | David Holtz, MD
I hope you’ve had an enjoyable summer and were able to take a break from the busy schedule we all keep in gynecologic oncology. In Washington DC, the Centers for Medicare & Medicaid Services (CMS) was busy preparing for next year and released the Medicare Physician Fee Schedule (MPFS) proposed rule for CY 2023 (CMS-1770-P) in July. I will summarize the most important points so that you can be ready for January 1st, 2023 and so you can reach out to your representatives on Capitol Hill to encourage change before these rules become finalized.
First, and of most concern is the cuts to Medicare payments for physician services. The change to the conversion factor for 2023 will decrease payment for work RVUs by 4.5% from $34.60 to $33.08. There may also be an additional 4% decrease in the overall federal spending budget due to pay-as- you- go rules which would also affect Medicare payments for physicians. The conversion factor decrease, set for 2022, was temporarily reduced by Congress, but that relief expires at the end of December. Congress annually waits until the very end of the year to enact legislation on this now annual payment problem that affects all physicians.
CMS proposed to adopt nearly all the revisions for CPT® codes used to report other E/M visits including inpatient/observation services and emergency department (ED) visits. The changes include revisions to the documentation guidelines and to the descriptors for these CPT codes, which will now mirror the outpatient E/M services. The E/M code level may be chosen based on time or medical decision making, and like the outpatient E/M codes, using the history and exam to determine code level has been eliminated, but should be performed when medically necessary.
In addition, CMS proposed to create new G codes (GXXX1, GXXX2 and GXXX3) to describe prolonged services for hospital, nursing facility and home visits, as they believe the CPT reporting guidelines for prolonged service 993X0 could lead to irregular payments, create administrative burden, and cause confusion on how to use 993X0. The use of the proposed G codes would apply to CPT codes used for hospital services and would allow the qualified health professional to bill in 15-minute increments for additional time above and beyond that of the highest level of E/M service.
There are many proposals for changes to telehealth services. Notably, Medicare will continue to support certain telehealth flexibilities through the end of 2023, although it is uncertain if Congress will authorize those telehealth flexibilities enacted during the pandemic. The agency is preparing to extend certain telehealth flexibilities, including the waiver of the originating site and geographic restrictions and coverage of audio-only services, for the 151- day period at the conclusion of the public health emergency as authorized by Congress CMS is also proposing to discontinue use of modifier- 95 after the telehealth extension period concludes, but CMS proposed to replace this by changing the point of service descriptor. A new modifier- 93 would be added for audio only communications. CMS is also requesting information about the use of direct supervision through virtual media.
Dr. Holtz is a gynecologic oncologist at Lankenau Hospital in Wynnewood, Pennsylvania