On July 7th, the Centers for Medicare & Medicaid Services (CMS) issued its annual proposed rule
that includes updates to payment policies, payment rates, and quality provisions for services furnished under the Medicare Physician Fee Schedule effective on or after January 1, 2023. AANEM staff drafted and submitted a 10-page comment letter
that addressed all pertinent aspects of the 2000+ page proposed rule, including calling on CMS to do everything in its power to avert drastic cuts to physician payments.
One of the biggest areas of concern in the proposed rule is the projected 4+% reduction in the Medicare conversion factor. While the reduction is due to statutorily-mandated budget neutrality rules, AANEM urged CMS to work with Congress and the medical community to provide a positive update to the Medicare conversion factor in 2023 and in all future years to counteract the negative impacts of inflation on physicians, medical practices, and patient access to care. Additionally, AANEM showed support for all efforts to mitigate the detrimental financial impacts of the 4% PAYGO sequester necessitated by passage of legislation unrelated to Medicare.
The second big issue in the proposed rule which AANEM commented on was CMS’ disagreement with the RUC proposed values for the neuromuscular ultrasound codes: 76881 (ultrasound, complete joint, real-time with image documentation), 76882 (ultrasound, limited, joint or other nonvascular extremity structure(s), real-time with image documentation), and the new NM US code 76XX0, which will be used to report real-time, complete neuromuscular ultrasound of nerves and accompanying structures throughout their anatomic course, per extremity. Instead, CMS has proposed RVUs that would result in drastic reductions in reimbursement for 76881 and are far less than the RUC recommended values for the other two. AANEM provided detailed rationale urging CMS to accept the RUC recommended values and halt further cuts to this code family.
The comment letter also addressed proposals to continue the expansion of telehealth, concerns with split (or shared) evaluation and management services, and various Quality Payment Program (QPP) proposals that could impact AANEM members. Please see the comment letter for more details.
Questions and comments are always welcomed by the AANEM policy department: email@example.com