CMS has released its highly anticipated tentative rule for governing the 2023 Medicare Physician Fee Schedule (MPFS). In turn, the American College of Radiology has posted a first-look summary focused on the schedule’s implications for medical imaging.
The proposed rule is open for public comment, and the final edition is expected to drop in the fall.
Here are five highlights from the ACR summary as posted by the college shortly after CMS went live with its proposal July 7.
1. Conversion Factor and CMS Overall Impact Estimates:
CMS proposes a $33.08 PFS conversion factor in 2023, a $1.53 decrease from the 2022 PFS. … CMS estimates an overall impact of the MPFS proposed changes to radiology to be a 3% decrease, while interventional radiology would see an aggregate decrease of 4%, nuclear medicine a 3% decrease and radiation oncology and radiation therapy centers a 1% decrease if the provisions within the proposed rule are finalized.”
2. Valuation of Imaging Services:
CMS addressed Relative Value Scale Update Committee (RUC) recommendations for 10 radiology-related CPT codes. They accepted the values for codes pertaining to contrast X-ray of knee joint, 3D rendering and interpretation, ultrasound guidance and fluoroscopic guidance. However, CMS proposed to refine the values for codes related to neuromuscular ultrasound and percutaneous arteriovenous fistula creation. The ACR will continue to review the proposed rule, including any practice expense refinements.”
3. Clinical Labor Update:
CMS proposed continuing to move forward with year 2 of the 4-year transition to the updated clinical labor input values. CMS updated wages for a few clinical staff types based on information submitted by stakeholders. The agency will continue to consider public comment related to wage updates for clinical staff during the remainder of the 4-year phase-in.”
4. Practice Expense Data Collection/Methodology:
CMS is seeking public comment on strategies for updates to practice expense (PE) data collection and methodology. CMS plans to move forward to a standardized and routine approach to valuation of indirect PE and they welcome feedback from stakeholders on what this might entail. CMS provided some specific topics in the rule on which they are seeking comment. The agency plans to propose the new approach to valuation of indirect PE in future rulemaking.”
5. Colorectal Cancer Screening Coverage:
The proposed rule does not make any mention of CT colonography for colorectal cancer screening. CMS recently responded to the ACR’s formal reconsideration request that there is not sufficient evidence to support changing the current non-coverage determination for CT colonography. The ACR will meet with CMS in the near future to discuss its rationale for the decision.”
CMS’s draft MPFS for 2023 also proposes particulars and provisions of the Medicare Shared Savings Program (MSSP) and Quality Payment Program (QPP). The ACR summary drills down into these as well, adding that it will continue to review the proposed rule and issue a more detailed summary soon.
Click here for ACR’s preliminary summary of the proposed rule, here for a CMS fact sheet and here for CMS’s press release.
Also, along with issuing the proposed rule, CMS is referring stakeholders interested in related Appropriate Use Criteria and Clinical Decision Support requirements to its webpages covering those topics at CMS.gov.
More Coverage of Physician Fee Schedule:
MedPAC recommends 0% physician pay update in 2023, drawing swift rebuke from docs
Lawmakers pressure congressional leaders to fix clinical labor update set to stifle radiologist pay
Hundreds of radiologists flood feds with pleas to avoid massive Medicare pay cuts
Medicare payments to physicians attributable to noninvasive diagnostic imaging are down
Dave P. has worked in journalism, marketing and public relations for more than 30 years, frequently concentrating on hospitals, healthcare technology and Catholic communications. He has also specialized in fundraising communications, ghostwriting for CEOs of local, national and global charities, nonprofits and foundations.