ACR applauds CMS for delaying ‘split/shared’ visit policy, warns about reimbursement cuts
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While praising CMS’ 2023 Medicare Physician Fee Schedule for offering more flexibility, the American College of Rheumatology has submitted comments of concern over proposed reimbursement cuts to critical rheumatology services.
In a comment letter to CMS dated Sept. 6, ACR stated it had concerns regarding a proposed 4.4% decrease — from $34.61 to $33.08 — to the calendar year 2023 conversion factor. Additionally, the fee schedule includes “drastic proposed cuts” to musculoskeletal ultrasound reimbursement, according to the ACR. Meanwhile, in the same letter, the ACR said it agrees with CMS’ decision to delay the “split/shared visit” policy.
“The ACR commends the Centers for Medicare and Medicaid Services (CMS) for its continued recognition of the value of complex medical decision-making provided by rheumatologists and other cognitive care specialists in the treatment of their patients,” Kenneth Saag, MD, MSc, president of the ACR, said in a press release. “However, we fear the significant harm that the decreased conversion factor will have on our rheumatology care team and our patients while they continue to recover from the stress of the past 2 years.”
The split/shared visit policy stems from a 2022 Physician Fee Schedule final rule allowing payment in which physician and non-physician providers deliver services together for a split/shared facility-based visit, including prolonged visits. According to the ACR, this policy would require a provider to deliver more than half of the care during such shared/spilt visits in order to bill for the services. The policy, the ACR argues, does not consider the proper role of medical decision-making and raised concerns regarding its potentially negative impacts on collaborative care.
CMS’ decision to delay the policy’s implementation until 2024 offers the flexibility to allow these visits to be billed based on either history, patient examinations or medical decision-making, or time, according to the ACR.
Additionally, the delay allows “physicians and [non-physician providers] to establish a more collaborative cadence in their visits that emphasizes the cognitive skills needed to provide the best care for their patients,” read the press release.
“Our nation's health care system continues to navigate the challenges of a global pandemic that has strained resources and providers,” Saag said in the release. “We appreciate the policies and flexibilities set forth by CMS to help alleviate these challenges and the agency’s attention to the concerns outlined by the rheumatology provider community while we all work to provide top quality patient care.”
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