Proposed Medicare Physician Fee Schedule for 2023 Includes Positive Changes for Internal Medicine Physicians

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Proposed fee schedule increases value for E/M codes, but ACP calls on Congress to prevent looming cuts to physician payments, which would offset the increased valuation

Aug. 12, 2022 (ACP) -- The American College of Physicians is pleased that the new proposed Medicare Physician Fee Schedule for 2023 adopts many of its recommendations about better recognizing the worth of primary care physicians in the U.S. health care system.

“We are particularly glad to see that the Centers for Medicare & Medicaid Services (CMS) included the increased value for evaluation and management (E/M) codes used in inpatient settings in the fee schedule,” said Dr. Ryan D. Mire, president of ACP. “The changes in these codes, combined with the changes made to outpatient E/M codes in 2021, are significant in recognizing the value that internal medicine physicians contribute to their patients and our health care system across a variety of health care settings.”

CMS released the proposed fee schedule in early July, and ACP immediately began to review its provisions and start the process of providing comments to CMS.

The agency's proposal to boost the value of E/M is “very good news,” said Shari Erickson, ACP chief advocacy officer and senior vice president. “We've been integrally involved along the way to ensure that those codes are aligned with the outpatient E/M codes.”

ACP is also pleased to see that the proposed fee schedule delays the implementation of complex changes to the way that physicians bill for “split” or “shared” E/M services that they provide jointly with a qualified health care professional, such as a physician assistant or nurse practitioner.

“This does happen quite a bit with hospitalist services,” Erickson explained. “For example, the hospitalist may provide some aspect of service, then a nurse practitioner comes in and provides care management. The proposed changes would be extremely burdensome. We had asked CMS to reassess that policy and, at a minimum, not implement it in 2023. So, this is a win for us, and something that we're really pleased to see.”

The proposed fee schedule also aims to extend physician compensation for the telehealth services that have been so crucial during the COVID-19 pandemic. ACP has pushed for CMS to allow the telehealth provisions to stay in effect so the benefit of the services to patients can be better understood.

“The increased use of telehealth services has been vital to providing care to my patients during the COVID-19 pandemic, but it can also serve as a tool to better meet the needs of patients in nonemergency times,” Mire said. “Allowing the expanded role for telehealth to continue has the potential to enhance patient-physician collaboration and increase access to care. We believe that telehealth should continue to be an important component of health care delivery.”

The proposed Medicare Shared Saving Program rule, which includes changes to address social drivers of health and improve health equity, also aligns with ACP recommendations and policy. ACP recently released a policy paper urging the federal government to overhaul the physician payment system to better address these same topics.

The rule also includes new Merit-based Incentive Payment System (MIPS) Value Pathways (MVPs) for 2023. Among the MVPs included for next year is the Promoting Wellness Pathway, which is similar to a pathway on Preventive Care that ACP had previously suggested to CMS when the agency was seeking feedback on the creation of MVPs. “We'll be closely reviewing the implementation to make sure it will really be helpful and meaningful to our members,” Erickson said.

However, the future is not entirely bright. ACP remains deeply concerned about the significant cut to physician payments that is proposed for Jan. 1. This would offset the proposed fee schedule's increased valuation of the E/M codes.

Congress has acted again and again in recent years to forestall annual cuts. “We need to find a solution that will prevent the cuts that are scheduled for next year, but it is also imperative that we find a long-term solution that addresses the structural problems in Medicare that cause repeated issues with payments under the fee schedule,” Mire said. “ACP will continue to advocate with Congress and the administration on both short- and long-term solutions. We will be further analyzing the details and impact of the proposed rule for next year and sharing our feedback with CMS.”

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