Proposed CMS 2023 Cuts Threaten Healthcare

Once again, proposed Centers for Medicare and Medicaid Services (CMS) cuts to the Physician Fee Schedule for 2023 threaten healthcare in the United States. The American College of Radiology (ACR) posted the five most likely CMS proposals to impact radiology practices in 2023. The CMS’s proposals became public on July 7.

• Physicians Fee Schedule (PFS) Conversion Factor. The CMS proposal of a $33.08 PFS conversion factor amounts to a $1.53 decrease compared to the 2022 PFS conversion factor. The CMS estimates this would amount to a 3% decrease for radiology, with a 4% decline for interventional radiology, 3% for nuclear medicine, and 1% for radiation oncology.
• CMS considered the Relative Value Scale Update Committee (RUC) reviewed recommendations for 10 radiology CPT codes and accepted values recommended for contrast X-ray of knee joint, ultrasound guidance and fluoroscopic guidance, and 3D rendering and interpretation. CMS has proposed refining values of the codes related to percutaneous arteriovenous fistula creation and neuromuscular ultrasound. ACR will consider monitoring the proposals.
• Updating Clinical Labor. CMS intends to continue into the second year of the 4-year transition to updated clinical labor input values. The agency has updated some wages for certain clinical types that stakeholders have submitted. CMS will continue to monitor public comments regarding wage updates for clinical staff over the remaining 4-year time frame.
• Updates for Practice Expense (PE) Data. CMS will seek public comment to develop approaches for updates to practice expense data collection and methodology. They intend to proceed with a standardized method for valuation of indirect practice expenses but welcome feedback from stakeholders. CMS has indicated that it plans to put forward a new approach to valuation of indirect PE in future determinations.
• Coverage for CT Colonography. Although ACR formally requested CMS to reconsider its position on their non-coverage determination for CT colonography, there is no reference to CT colonography in their proposed new rule regarding screening for colorectal cancer. ACR intends to meet again with CMS to discuss their decision.

In a press conference on July 13, Bob Still, executive director of the Radiology Business Management Association, addressed the implications of the CMS proposed cuts to the Physician Fee Schedule for 2023, “CMS couldn’t have picked a worse time to cut Medicare payments to physicians.

“We’re still in the midst of the pandemic, and patients who avoided regular health screenings are returning to doctors’ offices. And it’s that exact moment—when patients need us most—that Congress and the White House decide to introduce disastrous cuts.”

Still also noted that the cuts will produce incalculable damage to the medical profession and hurt vulnerable populations.

RBMA’s advocacy arm, the Radiology Patient Action Network, is front and center warning that these cuts, combined with expiring Congressional support, will “devastate patient populations throughout the United States.”

Still further explained, “This isn’t abstract for our physician members. They face huge patient backlogs, rising costs, and equipment shortages. And now, on top of all that, they face a massive cut from CMS and Congress. It’s simply unthinkable that policymakers would do this at a time when patients are waiting for life-saving procedures.”

RBMA maintains that all parties must seek a permanent solution to provide stability in the U.S. healthcare system — by seeking to implement an inflation escalator rather than continuing to emphasize budget neutrality.