Proposals aim for "whole-person" care, enhanced access to behavioral health and preventative services paired with overarching payment cut for physician services

On July 7, the Centers for Medicare & Medicaid Services (CMS) issued their Calendar Year (CY) 2023 Medicare Physician Fee Schedule (MPFS) Proposed Rule. The rule includes proposals intended to expand access to behavioral health services, cancer screening, and dental care — particularly in rural and underserved areas — as well as proposals advancing health equity and high-quality, whole-person care through care coordination and additional participation in Accountable Care Organizations (ACOs). "At CMS, we are constantly striving to expand access to high quality, comprehensive health care for people served by the Medicare program," said CMS Administrator Chiquita Brooks-LaSure. "[These] proposals expand access to vital medical services like behavioral health care, dental care, and cancer treatment options, all while promoting access, innovation, and cost savings in the Medicare program."

Among the proposed policies, CMS proposes changes to ACO benchmarks and metrics to sustain long-term participation and reward provision of care for underserved populations, also proposing payment flexibilities for certain ACOs to address patients' social needs. Other policies include those to enable additional non-physician professionals to provide general mental health care and bolster provision of opioid treatment from mobile vans, expand preventative service coverage for colonoscopies, broaden Medicare's narrow dental coverage definition, and expand access to audiology and chronic pain management services. CMS also proposes to delay the split (or shared) Evaluation and Management (E/M) visits policy finalized in CY 2022 to define the substantive portion of a visit based on the amount of time spent by the billing practitioner.

The rule also includes a 4.42% reduction of the conversion factor, the starting point for calculating Medicare payments for physician services. The conversion factor accounts for a statutorily required budget neutrality adjustment and the expiration of a 3 percent increase in physician payments for 2022 that was required by the Protecting Medicare and American Farmers from Sequester Cuts Act (S. 610). Provider groups are already pushing back on the proposed cuts. Jack Resneck, president of the American Medical Association (AMA) said in a statement 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." Similarly, the Surgical Care Coalition said the cuts "threaten patient care and are unsustainable for the long term."

Comments are due September 6, 2022.

Additional information is also available in the attached Tax Alert.

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Proposed CY2023 Medicare physician fee schedule