The Centers for Medicare & Medicaid Services (CMS) published the final 2023 Physician Fee Schedule (PFS) on Nov. 1, 2022, which institutes changes to both Medicare physician payments and quality reporting program policies that will take effect Jan. 1, 2023. The 2023 Final Rule can be accessed here: 2023 Medicare Physician Fee Schedule Final Rule

CMS states, “The calendar year (CY) 2023 PFS final rule is one of several rules that reflect a broader Administration-wide strategy to create a more equitable health care system that results in better accessibility, quality, affordability, and innovation.”

The confluence of conversion factor cuts, statutory cuts from sequestration and PAYGO rules, and a 0% payment update that fails to account for significant inflation in practice costs, further creates long-term financial instability in the Medicare physician payment system.

The final PFS conversion factor for calendar year (CY) 2023 is $33.0607. This is a reduction of $1.55, or almost 4.47%, to the CY 2022 PFS conversion factor of $34.6062, reflecting in part the expiration of the temporary 3% supplemental increase in fee schedule payments for CY 2022. Physician organizations and medical societies are continuing to engage with Congress to find a solution to mitigate these cuts before they go into effect.

If you have any questions or reactions to the final policies, Schedule your 1:1 consultation today with the Dagger Healthcare Consultants at info@daggerhealth.com or by calling (337) 842-5431.

Additional takeaways from this final rule include:

• Split/shared E/M billing requirements were delayed until CY 2024, permitting the billing clinician to bill for services based on history, exam, medical decision making, or time in 2023;

• Updating other E/M services including inpatient and observation visits, emergency department visits, nursing facility visits, domiciliary or rest home visits, home visits, and cognitive impairment assessments;

• Continuing payment for Medicare telehealth services that are temporarily included on the telehealth list for 151 days following the conclusion of the COVID-19 public health emergency and maintaining payment parity between in-person and telehealth visits through 2023;

• Introducing five new MIPS Value Pathways (MVPs) for a total of 12 MVPs available for voluntary reporting in 2023;

• Creating new upfront payments for certain low-revenue, new entrant accountable care organizations (ACOs) serving underrepresented populations to invest in increased staffing, social determinants of health strategies, and healthcare provider infrastructure;

• Permitting auxiliary personnel to furnish behavioral health services incident to a physician or non-physician practitioner services under general instead of direct supervision; and,

• Increased Qualifying APM Participant (QP) and partial QP threshold in performance year 2023.