The U.S. Centers for Medicare and Medicaid Services has released the proposed 2023 Medicare Part B Physician Fee Schedule. Here's a quick rundown of some of what's in the proposed rule. Expect a second article in the coming days that outlines additional provisions. (The second article is now published.)
Conversion Factor Cut
CMS proposes another decrease in the conversion factor, one of the elements used in calculating final payment amounts for various codes. This time around, the conversion factor is $33.0775, a 4.42% decrease from the $34.6062 conversion factor adopted in 2022. If finalized, the rule would result in the conversion factor dropping below early 1990s levels. The change is far-reaching, affecting more than 27 specialties including physical therapy.
The proposed rule maintains CMS' position that PTs and PTAs will only be permitted to provide services via telehealth through the duration of the coronavirus public health emergency (and an additional 151 days past the PHE tacked on by Congress). After that, none of the codes typically used by PTs will be included among the list of codes authorized for use in telehealth.
The agency did, however, add a number of codes to the "category 3" list of codes for which PTs can be paid when delivered via telehealth through 2023. As with all other category 3 codes, PTs' ability to bill these codes in association with telehealth will cease when the public health emergency and add-on days end or until midnight Dec. 31, 2023, whichever comes first.
Relative Value Unit Weighting
In the first such update in eight years, CMS is proposing to rebase and revise the Medicare Economic Index, which underlies the RVU practice expense component. The adjustment would make the practice expense portion of the RVU a larger portion of the total RVU calculation, which shapes final payment amounts. This is good news for PTs, as CMS projects the policy could increase payment for physical therapy by 2%. The earliest this policy could be implemented is 2024.
Remote Therapeutic Monitoring
APTA successfully advocated for a change, adopted by CMS in the 2022 fee schedule rule, that added five CPT codes for remote therapeutic monitoring. Three of the codes were designated for RTM services, while two — 98980 and 98981 — were aimed at RTM treatment management services. CMS is proposing that 98980 and 98981 be replaced with two new codes— GRTM3 (RTM treatment assessment services, first 20 minutes) and GRTM4 (RTM treatment assessment services, additional 20 minutes).
APTA is reviewing the rule and will submit comments by the September deadline. While the association will be advocating for the profession around the provisions in the proposal, we will continue to join other professional organizations to urge Congress to intervene again and provide additional funding to prevent cuts to the 2023 Fee Schedule. In addition, APTA will continue to coordinate with other provider groups to press for a full-scale reform of the entire physician fee schedule and Quality Payment Program systems.
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