Coding and Billing

CMS-Proposed Rule Changes for the 2023 Medicare Fee Schedule

By Mark Wright, OD, FCOVD,
and Carole Burns, OD, FCOVD

Sept. 7, 2022

On July 7, 2022, the Centers for Medicare & Medicaid Services (CMS) published the annual Medicare Fee Schedule proposed rule changes for 2023.i Some of the proposed changes include updates to physician payment, Evaluation & Management (E/M) changes, billing requirements for split or shared services and telemedicine updates.

Other changes are also proposed. We’ve limited the proposed changes in this article to those most likely to impact eyecare practices. Any changes finally approved will not be implemented until January 1, 2023. We will keep you in the loop as more information becomes available.

Updates to Physician Payment for 2023
The rule includes a reduction to the Conversion Factor from $34.6062 to $33.0775, which results in an effective 4.42 percent reduction in physician payment. The driver behind the payment change is to maintain budget neutrality, which is required by law to ensure payment rates for individual services do not result in changes to estimated Medicare spending.

Evaluation & Management (E/M) Changes
These changes are intended to reduce administrative burden similar to the approach finalized in the CY 2021 PFS final rule for office/outpatient E/M visit coding and documentation. The proposed revised coding and documentation framework would include CPT code definition changes including:

• New descriptor times (where relevant).
• Revised interpretive guidelines for levels of medical decision-making.
• Choice of medical decision-making or time to select code level (except for a few families like emergency department visits and cognitive impairment assessment, which are not timed services).
• Eliminated use of history and exam to determine code level (instead there would be a requirement for a medically appropriate history and exam).

Billing Requirements for Split or Shared Services
CMS proposes that clinicians who furnish split (or shared) visits will continue to have a choice of history, physical exam, medical decision-making or more than half of the total practitioner time spent to define the substantive portion, instead of using total time to determine the substantive portion, until CY 2024.

Telemedicine Updates
CMS proposes allowing telemedicine services to be furnished in any geographical area and in any originating site, including the beneficiary’s home. It also proposes allowing certain services to be furnished via audio-only telecommunications systems.

i. Calendar Year (CY) 2023 Medicare Physician Fee Schedule Proposed Rule | CMS

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