Nephrologists see some potential wins, losses in proposed Medicare rule for payment
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CMS has released a proposed rule for the 2023 Physician Fee Schedule with some mix results for nephrologists, according to the Renal Physician Association.
“ ... As usual, the news is mixed to positive for nephrology,” Robert Blaser, director of public policy for the RPA, wrote in an analysis for the association. “While the fee schedule conversion factor is projected for an approximate (and expected) 4.4% reduction, valuation for virtually all dialysis services (inpatient and outpatient, adult and pediatric, home and in-center, monthly and daily) either held steady or ticked up slightly,” he wrote.
“Further, the proposed and objectionable CMS change in the definition of ‘substantive portion’ for split/shared services has been delayed for an additional year, until January 1, 2024.”
Nephrology fees
Blaser wrote that the changes to the conversion factor (CF), which is the multiplier through which reimbursement increases or decreases in the fee schedule, “is set for a substantial decrease from the Congressionally fixed rate of approximately $34.60 to a yet-to-be-fixed rate of approximately $33.07.
“This was expected to be the case as it is in alignment with current law, and largely is comprised of the 3% increase that Congress added last winter to adjust for last year’s shortfall (due to budget neutrality), and an overall increase in inpatient evaluation and management (E&M) codes proposed for 2023,” Blaser wrote. “Again, organized medicine was anticipating this CF cut and has been pursuing advocacy on Capitol Hill with both short-term goals (to fix the 2023 cut) and longer-term objectives (to reduce or eliminate the impact of budget neutrality in the fee schedule, which is largely the cause of these reductions),” he wrote.
The decision by CMS to delay changes in payment to the split/shared services is based on the agency’s interest in more feedback on the proposal, Blaser wrote. “The agency reiterates their belief that their revised definition — basing substantive portion strictly on time, regardless of the impact of medical decision making — is appropriate, stating that, ‘While we continue to believe that the definition of substantive portion we finalized in the [calendar year] CY 2022 [Physician Fee Schedule] PFS final rule is appropriate, delaying implementation of this aspect of our policy would also allow for the changes in the coding and payment policies for other (evaluation and management) visits to take effect for CY 2023, and allows for a 1-year transition for providers to get accustomed to the new changes and adopt their workflow in practice. Additionally, this delay allows interested parties another opportunity to comment on this policy and gives us time to consider more recent feedback and evaluate whether there is a need for additional rulemaking on this aspect of our policy,’” Blaser wrote.
AV fistula codes
Blaser wrote the proposed rule includes development of two new payment codes for percutaneous AV fistula creation. “ ... CMS proposes to finalize both codes (which are still listed as ‘X’ codes for the moment),” he wrote. “However, in the proposed rule the agency does reduce the (Relative Value Scale Update Committee) RUC recommended work (relative value units) RVUs for both services, from 7.50 to 7.20 for 368X1 (the Ellipsys system), and from 9.60 to 9.30 for 368X2 (the Wavelinq system),” Blaser wrote.
The Ellipsys and the Wavelinq access devices are FDA-approved devices that have shown similar outcomes when used for dialysis access.
CMS said in a press release that the proposed rule would also significantly expand access to behavioral health services, accountable care organizations, cancer screening and dental care — particularly in rural and underserved areas.
“Integrated coordinated, whole-person care — which addresses physical health, behavioral health, and social determinants of health — is crucial for people with Medicare, especially those with complex needs,” Meena Seshamani, MD, CMS deputy administrator and director of the Center for Medicare, said in the release. “If finalized, the proposals in this rule will advance equity, lead to better care, support healthier populations and drive smarter spending of the Medicare dollar.”
To access an comment on the proposed rule, go to www.federalregister.gov/public-inspection/2022-14562/medicare-and-medicaid-programs-calendar-year-2023-payment-policies-under-the-physician-fee-schedule,
Reference:
CMS proposes physician payment rule to expand access to high-quality care. www.cms.gov/newsroom/press-releases/cms-proposes-physician-payment-rule-expand-access-high-quality-care. Published July 7, 2022. Accessed July 18, 2022.
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