Cuts in Physician Payments Will Reduce Access to Care
Cuts in Physician Payments Will Reduce Access to Care
The MGMA’s data shows that 90% of medical facilities reported likely declines in access to care following the 2023 payment cuts in the Medicare physician fee schedule.
After the significant changes to E/M services, we have to expect physician payment cuts. Moreover, the relevant changes in reporting are hitting telemedicine and audio-only services, according to the final 2023 Medicare Physician Fee Schedule. (https://www.cms.gov/files/document/)
Notwithstanding vocal criticism from the physician advocacy groups, proposed payments will move forward as planned.
Due to the expiration of the 3% pay increase provided by Congress and changes to E/M Current Procedural Terminology codes in 2022, in 2023 convention factor will be reduced by 4,47% to $33,06 (by comparison in 2022, it was $34,61). Many organizations are demanding that Congress take action to stop these decreases by implementing an inflationary physicians’ update and waiving the 4% pay-as-you-go sequester.
Anders Gilberg, the MGMA Senior Vice President of Government Affairs, says, "As expected, CMS finalized a substantial reduction to the conversion factor — negatively impacting physician reimbursement across the board. It is more critical than ever that Congress act to avert these cuts, as well as the 4% PAYGO sequestration, before the end of the year. Ninety percent of medical practices reported that the projected reduction to 2023 Medicare payment would reduce access to care. This cannot wait until the next Congress—there are claims processing implications for retroactively applying these policies. MGMA looks forward to working with both Congress and the Administration to mitigate these cuts and develop sustainable payment policies to allow physician practices to focus on treating patients instead of scrambling to keep their doors open."
His opinion is shared by Jack Resneck Jr., M.D. president of the American Medical Association (AMA). Jack notes the same complaints and believes it will double the negative impact on accessing health care.
"The Medicare payment schedule released today puts Congress on notice that a nearly 4.5 percent across-the-board reduction in payment rates is an ominous reality unless lawmakers act before January 1. The rate cuts would create immediate financial instability in the Medicare physician payment system and threaten patient access to Medicare-participating physicians. The AMA will continue working with Congress to prevent this harmful outcome," Resneck says.
Updates of E/M, Telemedicine, and More
In its final rule, the CMS specified that it would adopt the framework of the AMA's revised E/M guidelines for facility and residential visits. This will also include payment based on medical decision-making or time.
CMS adopted the telehealth waiver extension passed by Congress in the Consolidated Appropriations Act of 2022. This extension blocks a large number of telehealth waivers (like audio or geographic waivers, as well as the ability of therapists, occupational therapists, speech-language pathologists, and audiologists to bill such codes under telehealth) within 151 days of PHE expiration.
The innovations will also affect MIPS. In 2023, the category weight will be 30% for Quality, 30% for Cost, 15% for Improvement Activities, and 25% for Promoting Interoperability. Also, the data completeness threshold will increase from 70% to 75%.
The current MIPS structure will be eventually replaced by the MVP program (MIPS Value Pathways), for which CMS will already take applications. To the agency's seven existing MVPs, five more will be added. It can be possible that for the 2023 performance year, eligible clinicians will no longer be able to earn the 5% Advanced Alternative Payment Model (APM) bonus payment or the MIPS exceptional performance bonus. It will depend on whether or not Congress passes legislation extending these bonuses.
ACOs with low revenue, treating underserved communities with advance investment payments, will receive money from CMS as it was proposed. "Greater flexibility in the progression to performance-based risk" will be provided by the agency to some ACOs. "Allowing these organizations more time to redesign their care processes to be successful under risk arrangements," a CMS press release says.
The voluntary reporting incentive eCQMs/MIPS CQMs will be expanded by CMS till 2024 (there will be a replacement of the Web Interface reporting method for all Shared Savings ACOs by this time) and introduce a "health equity adjustment" for Medicare Shared Savings Program (MSSP) efficiency reporting.
"Premier applauds CMS for finalizing reforms to certain aspects of the MSSP that incentivize provider participation. As Premier has long advocated, we must ensure that providers in ACOs have an adequate budget and that we create incentives for rural and other vulnerable providers to move to value. We remain disappointed, however, that CMS is continuing to distinguish between low- and high-revenue for ACOs, especially in light of a Premier analysis demonstrating the differences between ACOs have more to do with cherry-picking locations and attribution methodology than with real performance," Soumi Saha, senior vice president of government affairs at Premier, said in a release.
A similar comment was made by the President and CEO of the National Association of ACOs (NAACOS), Clif Gaus, Sc.D. He said, "Today’s finalized changes to Medicare’s largest ACO program bring a win to patients and will absolutely help providers deliver accountable care to more beneficiaries. NAACOS thanks CMS for its leadership and for following through on its promise to create a stronger Medicare program by improving accountable care models and speeding the movement toward value for all patients. On balance, we believe this final rule will grow participation in accountable care organizations, which have already generated billions of dollars of savings for our health system."