Therapy teams take note: CY 2023 Medicare Physician Fee Schedule Final Rule
It’s that time of year again! Medicare has released the calendar year 2023 final rule related to Medicare Part B, which is impacted by the physician fee schedule and determines rates and coding updates for your rehab providers.
So what should your therapist know regarding the conversion factor, telehealth provisions, audiology services and remote therapeutic monitoring codes?
CY 2023 PFS rate setting and conversion factor
CMS finalized standard technical proposals involving practice expense, including the implementation of the second year of the clinical labor pricing update. Per statutory requirements, they also updated the data used to develop the geographic practice cost indices (GPCIs) and malpractice RVUs.
With the budget neutrality adjustments, which are required by law to ensure payment rates for individual services don’t result in changes to estimated Medicare spending, the required statutory update to the conversion factor for CY 2023 of 0%, and the expiration of the 3% supplemental increase to PFS payments for CY 2022, the final CY 2023 PFS conversion factor is $33.06, a decrease of $1.55 to the CY 2022 PFS conversion factor of $34.61.
Telehealth services
For CY 2023, they finalized a number of policies related to Medicare telehealth services, including making several services that are temporarily available as telehealth services for the PHE available at least through CY 2023 in order to allow additional time for the collection of data that may support their inclusion as permanent additions to the Medicare Telehealth Services List.
They finalized the proposal to extend the duration of time that services are temporarily included on the telehealth services list during the PHE for at least a period of 151 days following the end of the PHE, in alignment with the Consolidated Appropriations Act, 2022 (CAA, 2022).
Furthermore, they confirmed their intention to implement the telehealth provisions in sections 301 through 305 of the CAA, 2022, via program instruction or other subregulatory guidance to ensure a smooth transition after the end of the PHE.
These policies, such as allowing telehealth services to be furnished in any geographic area and in any originating site setting (including the beneficiary’s home); allowing certain services to be furnished via audio-only telecommunications systems; and allowing physical therapists, occupational therapists, speech-language pathologists and audiologists to furnish telehealth services, will remain in place during the PHE for 151 days after the PHE ends.
Audiology services
CMS finalized a policy to allow beneficiaries direct access to an audiologist without an order from a physician or NPP for non-acute hearing conditions.
The finalized direct access policy will allow beneficiaries to receive care for non-acute hearing assessments that are unrelated to disequilibrium, hearing aids or examinations for the purpose of prescribing, fitting or changing hearing aids.
CMS finalized the proposal to permit audiologists to bill for this direct access (without a physician or practitioner order) once every 12 months per beneficiary. Medically reasonable and necessary tests ordered by a physician or other practitioner and personally provided by audiologists will not be affected by the direct access policy, including the modifier and frequency limitation.
Remote Therapeutic Monitoring services
In the proposed rule, CMS presented two new G-codes for RTM services for use under the MPFS. However, after considering extensive stakeholder comments, CMS will not implement the G-codes and will maintain payment for the existing Current Procedural Terminology (CPT) codes (98980 and 98981) for RTM treatment management services.
As a result, therapists currently reporting CPT codes 98980 and 98981 will see no change to Medicare coding and billing requirements for RTM treatment management services in 2023.