July 14, 2022
The Centers for Medicare and Medicaid Services (CMS) released its 2023 Medicare Physician Fee Schedule (MPFS) Proposed Rule on July 7. The agency also created a 2023 MPFS fact sheet.
Unlike the Medicare Physician Fee Schedules of CY2021 and CY2022 which brought significant changes for PET, particularly non-oncologic PET, the CY 2023 proposed rule did not include similar changes. Not mentioned in the proposed rule is the removal or retirement of national non-coverage for amyloid PET and/or retiring national non-coverage for NaF PET. This year SNMMI held multiple meetings with CMS on the negative impact of national non-coverage determinations for both NaF and amyloid tracers and submitted comments. We will continue to advocate for these changes in coverage.
Items that are important for SNMMI members to be aware of in this proposed rule include the following:
A preliminary summary of the proposed rule proposes a 3.0775 PFS conversion factor in 2023, which is about $1.53 decrease from the 2022 PFS. CMS estimates an overall impact of the MPFS proposed changes to radiology and nuclear medicine to be a 3% decrease, and radiation oncology and radiation therapy centers a 1% decrease if the provisions within the proposed rule are finalized.
Therefore, this conversion factor issue affects all of medicine, and the SNMMI will join other societies in opposing this to avert general reductions across all services.
CLINICAL LABOR CHANGES
CMS proposed continuing to move forward with year 2 of the 4-year transition to the updated clinical labor input values. CMS updated wages for a few clinical staff types based on information submitted by stakeholders. The agency will continue to consider public comment related to wage updates for clinical staff during the remainder of the 4-year phase-in.
PRACTICE EXPENSE DATA COLLECTION & METHODOLOGY FOR CALCULATIONS
CMS is seeking public comment on strategies for updates to practice expense (PE) data collection and methodology. The agency plans to move forward to a standardized and routine approach to valuation of indirect PE, and they welcome feedback from stakeholders on what this might entail. CMS provided some specific topics in the rule on which they are seeking comment. The agency plans to propose the new approach to valuation of indirect PE in future rulemaking. Of importance, there may be a survey of indirect practice expense in the future. In the current methodology, nuclear medicine is cross-walked to radiology for the purposes of indirect practice expense. This is important because the indirect expenses for practice are significant and need to be accounted for.
ABSENT IN THE MPFS PROPOSED RULE
The MPFS proposed rule does not mention the Appropriate Use Criteria Program or Clinical Decision Support implementation. However, CMS published a statement saying that the payment penalty phase will not begin January 1, 2023, even if the PHE for COVID-19 ends in 2022. Until further notice, the educational and operations testing period will continue. CMS added that they are unable to forecast when the payment penalty phase will begin. We are grateful to the agency for this extension.
SNMMI continues to review the proposed rule and will provide our comment letter in the coming days. A chart of important nuclear medicine services may be found here.