On July 7, the Centers for Medicare and Medicaid Services (CMS) issued the display copy of the FY 2023 Medicare Physician Fee Schedule Proposed Rule.
Below AHCA has provided a brief summary of some of the key physician fee schedule proposed rule provisions on the 2,066 page document:
- Proposed -4.4% adjustment to the conversion factor - essentially a reduction to the base rate
- Part B therapies (PT/OT/SLP) look like an additional 1% cut added to the above (net -5.4%) to keep budget neutral due to redistribution between provider specialties
- Proposal to update the Medicare Economic Index (MEI) (from 2006 to 2017 base year) for CY 2023 payments which may potentially have more negative net impacts on Part B services in SNF as total payments can’t increase with redistribution
- Some improvements to telehealth services including keeping some therapy services on the telehealth services list until end of CY 23 – however, therapists by statute can only furnish for 151 days after end of PHE – so will need some legislative help to benefit from the proposed policy.
- Proposal to relax some supervision requirements for behavioral health, and expanded providers able to furnish such services.
- Proposed improvements to chronic pain management and expanded oral health dental services.
- Proposed ACO changes to facilitate expansion – particularly into rural and underserved areas.
- Proposed change to SNF provider enrollment regulations and the SNF Categorical Risk Designation which would require initially enrolling SNFs and revalidating SNFs to be subject to moderate risk-level screening which would require all SNF owners with 5 percent or greater ownership to submit fingerprints for a criminal background check.
Links to key CMS documents related to proposed rule:
Comments to CMS prior are due on September 6, 2022.