2023 Proposed PFS Rule Policies Examined

As discussed last month, the 2023 Medicare Physician Fee Schedule (PFS) rule has arrived, released by the Centers for Medicare & Medicaid Services (CMS) on Tuesday, July 7, 2022. The proposed rule outlines potential updates to a variety of policies and provisions that dictate payment for many services included in the Quality Payment Program (QPP), the Merit-Based Incentives Payment System (MIPS), and Advanced Alternative Payment Models (APMs). Again, know that these policies are proposed and will not be made final until the release of the final rule. Here we examine more impacts of potential rulemaking.

2023 MIPS Value Pathways and MIPS Scoring Insight

The ruling is seeking to reduce proposals for traditional MIPS. Instead, they aim to make greater specifications with implementation of MIPS Value Pathways (MPVs). Expect to see five new MVPs in the works with six receiving revised. Understand that the changes are focused on MVP maintenance and participation options including several additions and revisions to subgroup.

CMS MVP proposals include changes and clarifications to MVP maintenance and participation options, as well as multiple additions and revisions to subgroup reporting. This includes factors such as:

  • eligibility
  • registration
  • and scoring.

For MIPS scoring, no true adjustments are anticipated. The weights are projected to remain stagnant and unchanged since 2022:

  • Quality 30 percent,
  • Cost 30 percent
  • PI 25 percent
  • IAs 15 percent.

The ACR believes that “These percentages are likely to remain fixed for the future of the MIPS program. The proposed rule continues to offer category reweighting for physicians who are unable to submit data for one or more performance categories. In most cases, the weight of these categories will continue to be redistributed to the Quality category.”

Starting in 2022, CMS decided to calculate the MIPS performance based on previous years mean and/or median scores. As of 2022, the threshold stood at 75 points with CMS projected to maintain this threshold through 2023. The decision is founded upon the rounded mean score in the 2019 performance year. As of the start of next year, CMS will not provide for an exceptional performance adjustment as per the policies in the final 2022 MPFS rulemaking. According to the ACR, “CMS finalized the payment adjustment of +/- 9 percent for performance years 2020 and beyond. No changes have been proposed to the MIPS adjustment.”

Clinical Labor Update Looking Into 2023

Expect that CMS will continue going forth with the second year of what is designated as a four-year transition to updated clinical labor input values. CMS made some updates for wages to some minimal clinical staff types, founded upon information given by stakeholders. CMS is expected to be open for public comment when it comes to future wage updates for clinical staffing during the rest of the phase-in period.

However, the radiology community is about to be set for another year of reimbursement suffering if the proposed rule becomes final law or if further legislation isn’t passed. For 2023, CMS is projecting a conversion factor of $33.0775 as opposed to the 2022 conversion factor of $34.6062. The ACR notes that the calculations were made by “first removing the one-year 3 percent increase provided by the Protecting Medicare and American Farmers from Sequester Cuts Act and then applying a negative 1.55 percent budget neutrality update. The budget neutrality update appears to be largely related to increased values for several evaluation and management code families, including hospital, emergency medicine, nursing facility and home visits.”

The Future for Practice Expense Data Collection/Methodology

CMS is searching for public opinion on plans to tackle changes to practice expense (PE) data and collection methodology according to the ACR. Even more, according to the ACR, “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 comments. The agency plans to propose the new approach to valuation of indirect PE in future rulemaking.”

These are not all the impacts of the proposed PFS policy. Explore more regulatory, policy, and coding knowledge to master compliance and coding with our monthly Radiology Compliance Manager.

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