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The U.S. Centers for Medicare and Medicaid Services has released the proposed 2023 Medicare Part B Physician Fee Schedule. In the first part of our recap, we covered cuts to the conversion factor, the status of telehealth for PTs and PTAs, relative value unit weighting, and proposed changes to remote therapeutic monitoring codes. Here's a quick rundown of more elements of the proposed rule.

Merit-based Incentive Payment Program
CMS isn't proposing any major changes around MIPS eligibility, which means that again in 2023 most PTs who provide services to Medicare beneficiaries won't be required to participate. Also unchanged: MIPS weighting at 30% for quality performance, 30% for cost performance, 15% for improvement activities, and 25% for promoting interoperability. Similar to the eligibility criteria, this won't affect PTs, who have no avenue for reporting cost measures, resulting in the cost performance category being reweighted to 0%.

The proposal also continues to exempt PTs from reporting on interoperability for another year; however, CMS says that exemption will end in 2024. Still, the end of the exemption won’t change the fact that many PTs can qualify for the small practice exception. If a practice has 15 or fewer eligible clinicians, the practice will remain exempt from reporting on the promoting interoperability category.

For the relatively small number of PTs who are required to report to MIPS, a few changes are proposed: an increase in the data completeness criteria from 70% to 75% beginning with the 2024 performance period, the inclusion of health equity quality measures as a high-priority measure, and the addition of nine new quality measures. Those new measures include three that PTs may use (urinary incontinence, rheumatoid arthritis, and screening for social drivers of health).

MIPS Value Pathways
As expected, CMS plans to activate the MVP program in 2023, but PTs won't be eligible to participate. The proposed rule adds five new pathways — advancing cancer care, optimal care for kidney health, optimal care for neurological conditions, supportive care for neurological conditions, and promoting wellness — and updates some of the MVPS created for 2022. APTA continues to work with partners to create an MVP that would allow PTs to participate in a meaningful way with the least administrative burden.

Direct Supervision Conducted Virtually
CMS isn't proposing to make virtual direct supervision permanent, so for now, the allowance will be tied to the coronavirus public health emergency. The proposed rule does, however, ask for comments on whether the practice should be made permanent, and for which specialties. APTA supports offering as much supervision flexibility as possible, and is working for passage of the SMART Act (H.R. 5536) that would establish general supervision of PTAs under Medicare Part B.

Practice Expense Calculation and Changing Business Environments
The proposed rule calls for comment and information on issues that could affect the calculation of practice expense, including business arrangements and the use of technology. Market consolidation, workforce issues, and the types of business entities now operating in health care markets are on the table as potential factors, according to CMS.

New Code for Chronic Pain Management and Treatment
CMS is proposing a new code related to chronic pain, and while PTs likely won't be able to bill for the code, the code at least requires "ongoing communication and care coordination between relevant practitioners furnishing care (eg physical therapy)," opening the possibility of increased access to physical therapy for individuals with chronic pain. APTA will be advocating to CMS that physical therapy is a critical component of chronic pain management and many PTs act as the primary provider for patients with chronic pain, particularly pain associated with musculoskeletal issues.

Next Steps

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.

Keep up with APTA's advocacy efforts: Sign up for the APTA Advocacy Network, a free, members-only service that sends you special legislative updates and action alerts so you're up to speed and ready to act.


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