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CMS Proposed Physician Payment Role Designed to Expand Access to Quality Care

CMS issued the Calendar Year 2023 Physician Fee Schedule (PFS) proposed rule

July 13, 2022The Centers for Medicare & Medicaid Services (CMS) issued the Calendar Year 2023 Physician Fee Schedule (PFS) proposed rule on July 7, 2022. If finalized, the proposed rule would expand access to behavioral health services, accountable care organizations (ACOs), cancer screening, and dental care. 

Access to these services would be significantly expanded in rural and underserved areas, which is a priority for the Biden-Harris Administration. The Biden-Harris Administration’s Unity Agenda promotes advancing health equity and driving whole-person, high-quality care for all. 

PFS Proposed Rule Reduces PFS Conversion Factor, Modernizes Behavioral Health Services, and Expands ACO Access

The PFS proposed rule reduces the 2023 PFS conversion factor by $1.53, to $33.08. This change accounts for the required update to the conversion factor for CY 2023 of 0% and the expiration of the 3% increase in PFS payments for CY 2022 as required by the Protecting Medicare and American Farmers From Sequester Cuts Act. It also includes the required budget neutrality adjustment to account for changes in Relative Value Units.

The 2022 CMS Behavioral Health Strategy, CMS set goals to remove barriers to care and improve access to, and the quality of, mental health and substance use care. To address the shortage of practitioners providing these services, CMS proposes to allow licensed professional counselors (LPCs), marriage and family therapists (LMFTs) to provide behavioral health services under general supervision. The PFS proposed rule would also allow CMS to pay for integrated behavioral health services delivered by clinical psychologists and licensed clinical social workers through a patient’s primary care team.

The PFS proposed rule would also expand access to ACOs by making changes to the Medicare Shared Savings Program (MSSP). The MSSP provides care to over 11 million beneficiaries and includes over 500,000 providers. The proposed rule would incorporate advance shared savings payments to certain new Medicare Shared Savings Program ACOs.  A health equity adjustment would also be included in an ACOs quality performance score to award quality care delivered to underserved populations. Benchmark adjustments would also be included to encourage more ACOs to participate in the MSSP.

PFS Proposed Rule Gains Support from ACOs, But Others Are Wary

The CY 2023 PFS proposed rule has gained support from several organizations, notably ACOs that are happy with proposed changes to the Shared Savings Program. The National Association of Accountable Care Organizations (NAACOS) is also applauding the potential changes. 

“NAACOS sends a big bravo to the Centers for Medicare and Medicaid Services (CMS) for taking steps to reach its goal of creating a stronger Medicare by strengthening accountable care models and speed the movement toward value for all patients,” said NAACOS president and CEO Clif Gaus in a press release. “While we are still studying the major changes, policies in today’s proposed Physician Fee Schedule will help grow participation in . . . [ACOs], helping realize the CMS Innovation Center’s recent Strategy Refresh to have every Medicare beneficiary in a relationship with a provider accountable for his or her quality and total cost of care by 2030.”

While many ACOs are in support of the proposed rule, physician groups are wary of the change due to the proposed cuts to physician reimbursement. Some believe that this will have the opposite effect and threaten access to care for patients. 

“It is immediately apparent that the rule not only fails to account for inflation in practice costs and COVID-related challenges to practice sustainability, but also includes a significant and damaging across-the-board reduction in payment rates,” Jack Resneck Jr., MD, president of the American Medical Association (AMA), said in a statement. “Such a move would create long-term financial instability in the Medicare physician payment system and threaten patient access to Medicare-participating physicians. We will be working with Congress to prevent this harmful outcome.”

Joseph C. Cleveland Jr., MD, chair of The Society of Thoracic Surgeons Council on Health Policy and Relationships, also added, “The current Medicare Physician Fee Schedule is broken. It fails to incentivize collaboration and pits doctor against doctor every year.”

It is clear that there are differing opinions on the PFS proposed rule. Comments on the proposed rule are due September 6, 2022.

For a fact sheet on the CY 2023 Physician Fee Schedule proposed rule, click here

To access the CY 2023 Physician Fee Schedule and Quality Payment Program proposed rule in its entirety, click here

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