CMS Final Rule for 2023 Physician Fee Schedule Gets Mixed Reactions

(UPDATED) Following this week’s release by the US Centers for Medicare & Medicaid Services (CMS) of its final rule for the 2023 Physician Fee Schedule (PFS), cardiology societies see both positives and negatives.

Proposals that came out over the summer had many cardiologists worried about cuts, especially to procedural services, in an effort to gain budget neutrality.

Speaking with TCTMD, American College of Cardiology (ACC) President Edward T. A. Fry, MD (Ascension Indiana St. Vincent Heart Center, Indianapolis, IN), called the final rule “a good news, bad news scenario. The good news is that the adjustments are less draconian than what had been initially proposed. . . . The bad news [is] reflective of just the entire process.”

The more than 3,000-page document outlines several changes for 2023, including cutting the conversion factor from $34.61 to $33.06, which will lead to an estimated 1% decrease in overall cardiology reimbursements compared with 2022. The agency has also ruled to extend reimbursement for telehealth services for at least 5 months following the end of the public health emergency.

Fry said he was happy to see the extension for telehealth services but wished for “greater stability” there in the future so that health systems and providers can “know what the ground rules are going to be and really take advantage of things like telehealth and build the investments that are going to be necessary.”

In a statement released by the Society for Cardiovascular Angiography and Interventions (SCAI), the organization’s president, Sunil V. Rao, MD (NYU Langone Health, New York), said the final rule “stands in direct opposition to this Administration's stated goal of expanding access to vital prevention and treatment services.” Further, he said, "these proposed cuts are draconian and, if implemented, will roll back Medicare conversion factor rates to levels not experienced since 1997."

With similar sentiments, Joseph C. Cleveland Jr, MD (University of Colorado Anschutz Medical Center, Denver), chair of the Society of Thoracic Surgeons’ (STS) Council on Health Policy and Relationships, told TCTMD in an email: “The myriad pressures facing our country’s healthcare system grow with each year, yet instead of pursuing long-term reform to stabilize the system, the annual cuts to Medicare further exacerbate the issue.”

A statement published by the Surgical Care Coalition, of which the STS is a member, stated that cuts to surgery and anesthesia care will reach nearly 4.5% in 2023. It also called for Congress to pass legislature—specifically H.R. 8800, the Supporting Medicare Providers Act of 2022—before the end of the year to “protect patient access to surgical care.”

Likewise, the American College of Physicians (ACP) published a statement urging Congress to act to prevent additional cuts, albeit lauding CMS for making other “more encouraging” changes for internal medicine physicians, including payment increases for inpatient evaluation and management (E/M) codes. Additionally, while the ACP was happy to see a 1-year delay of the implementation of shared E/M billing for when multiple physicians see a patient at the same time, the statement said, “the delay to 2024 is not long enough, nor does the policy account for the physician contribution to those visits.”

Disappointing Cuts

Within the field of electrophysiology specifically, CMS will implement RVUs for supraventricular tachycardia, ventricular tachycardia, and atrial fibrillation ablation that are 11.2% higher than what was originally proposed but still 3.7% lower than those used this year.

In a joint statement, the ACC and the Heart Rhythm Society say that they “remain disappointed that the agency did not go further in amending the proposed cuts for key electrophysiology ablation services to reflect higher values derived within the established [AMA Relative Value Scale Update Committee] survey process, recognizing the high degree of skill and lengthy period of training required to perform these complex services, the enhanced safety despite increasingly sick patients, improved quality outcomes, and greater clinical value. These ongoing cuts, as well as structural cuts to all Medicare services, continue to threaten patient access to important, high-value cardiovascular services and underscore the need for not just short-term fixes, but long-term overarching reimbursement reform.”

Fry said he is “happy” with how collaborative advocacy was successful in reversing part of the proposed cuts. “Work that was done by many people—a lot of grassroots efforts, a lot of taking advantage of the societies’ ability to interact with regulators and legislators—did have results that prove that working together is a good idea,” he said.

“The biggest takeaway is that this just shines a bright light on the entire process of the way that we value care, physician work, and the work of health institutions,” Fry continued. “This really is now strong incentive for us to say we really have to drill down and find better ways. . . . We've talked about value for 10 years, [but] we haven't seen anything that's really substantively made a difference there.”

He said that “fundamental, structural issues” remain regarding patient access to quality care. “This is a clarion call to really reexamine healthcare reimbursement and the payment models overall,” Fry said, “and a call for innovation, pilot projects, and innovative solutions.”