On July 7, 2022, the Centers for Medicare & Medicaid Services (CMS) published the annual Medicare Physician Fee Schedule proposed rule describing proposed payment and policy changes for 2023. AAPM&R is currently reviewing the rule in detail and will provide specifics regarding proposed changes to RVU values and payment for physiatric services in the coming weeks. Key elements are described below including:

• Updates to physician payment for 2023
• Evaluation and management (E/M) changes
• Billing requirements for split or shared services
• Telehealth updates
• New coding for chronic pain management services

Updates to Physician Payment

Of immediate concern, the rule includes a reduction to the Conversion Factor from $34.6062 to $33.0775, a 4.42% reduction.

• This is primarily due to the expiration of a one-year 3% increase in payments, approved by Congress at the end of last year. The additional 1.42% cut is due to updates to several E/M code families, including inpatient hospital visits and nursing facility visits. Increases to codes in these E/M code families must be offset by a reduction in the conversion factor.
• AAPM&R continues to express concerns to Congress and CMS about the annual threat of cuts to physician payment and the lack of increases to payment commensurate with inflation and increased costs of running a medical practice and this issue was emphasized during our recent Hill Day. This will continue to be an advocacy priority for AAPM&R and organized medicine for the remainder of the year and beyond.

E/M Changes

Effective January 1, 2023, CMS proposes to accept revisions made by the AMA CPT Editorial Panel to update guidelines and code descriptors for several E/M families including inpatient hospital visits and nursing facility visits.

• Updates, which are available in detail on the AMA website, are similar to the updates made to office visit E/M codes which went into effect January 1, 2021, with an emphasis on streamlining documentation to reduce provider burden. CMS has also proposed adopting recommended updated RVUs for several of the codes, including some increases.
• AAPM&R’s CPT and RUC volunteers played an important role in these updates, ensuring that physiatry’s voice was heard in the code and guidelines revisions as well as in the updated code values. Your Academy will be developing educational resources to help guide the transition to the new documentation requirements.

Split (or Shared) E/M Visits

We are pleased to share that following AAPM&R’s significant advocacy effort, CMS has decided to delay its 2023 changes to the split (or shared) visits policy for one year.

• In 2023, CMS proposes to maintain the current policy, which allows the substantive portion of a visit to be met by either history, physical exam, medical decision-making or time.
• AAPM&R plans to continue to engage with CMS on developing an appropriate split (or shared) E/M policy, which should take into consideration the importance of team-based care while appropriately recognizing the significant value of physician medical decision-making.

Telehealth Updates

CMS proposes to implement telehealth provisions of the Consolidated Appropriations Act of 2022, which requires that certain telehealth flexibilities remain in effect for 151 days after the public health emergency ends.

• Critically, this requires extension of the flexibility which allows telehealth services to be furnished in any geographic area and in any originating site setting.
• AAPM&R continues to advocate for expanded telehealth coverage, including elimination of the site of service requirement and permanent continuation of payment parity.

Chronic Pain Management Services

CMS proposes several new codes for chronic pain management and treatment services to take effect in 2023.

• The codes describe a bundle of services provided to chronic pain patients over the course of a month, rather than separately capturing the individual interventions provided.
• AAPM&R is analyzing this proposal and its potential impact on our members who treat patients with chronic pain. We are pleased that the challenges of caring for this patient population are being acknowledged by CMS.

A comprehensive fact sheet about the rule is available on the CMS website.

If you have specific questions about the proposed rule, please email healthpolicy@aapmr.org.