This afternoon, the Centers for Medicare and Medicaid Services (CMS) released the calendar year (CY) 2023 Medicare Physician Fee Schedule (MPFS) proposed rule. For CY 2023, CMS proposes an MPFS conversion factor of $33.0775. That represents a 4.42% reduction from the CY 2022 MPFS conversion factor due to the expiring 3.0% boost to the conversion factor provided by Congress for CY 2022 as well as an additional budget neutrality adjustment generated by the CY 2023 proposed policies.
- Emergency Medicine Overall Impact. CMS estimated that the overall impact of the rule on emergency medicine is a 1% increase in payments. However, note that this estimate does not factor in the expiring CY 2022 congressionally-mandated 3% boost to the conversion factor.
- ED E/M Codes: Generally speaking, CMS proposes to adopt the revised CPT documentation guidelines for emergency department (ED) evaluation and management (E/M) visits. These changes are intended to align documentation for all E/M code sets (other than critical care services) with the documentation guidelines adopted for office and outpatient E/Ms in CY 2021. (For more information on the ED E/M documentation guideline changes coming January 1, 2023, see information from AMA CPT via this link.)
Because of these documentation guideline changes, the AMA RUC also embarked on a revaluation of all affected codes sets. In this proposed rule, CMS proposes to accept the values for emergency department (ED) evaluation and management (E/M) services as recommended by the AMA RUC for CPT 99281, 99282, 99283, and 99285. However, CMS rejected the RUC recommendation of 2.60 for CPT 99284 and instead proposes to maintain the current work RVU of 2.74.
- Split (or Shared) Visits. CMS had previously finalized a new January 1, 2023 billing policy for instances in which a physician delivers an E/M service along with a non-physician practitioner. As EDPMA requested, CMS has delayed the policy that would have based the determination of the billing practitioner solely on time. This policy is proposed for delay through January 1, 2024 while CMS collects additional input.
- QPP. Per usual, CMS proposes modifications to the reporting requirements under the Quality Payment Program (QPP), including the Merit-based Incentive Payment System. As a reminder, CY 2023 reporting under the QPP will affect payment adjustments for services furnished in CY 2025.
EDPMA will continue to analyze the proposed rule and provide additional details. EDPMA plans to comment on the proposed rule before the end of the 60-day comment period.