Proposed Medicare Fee Schedule Includes Physician Pay Cut, Expanded Access to Care
By Emma Freer

The recently proposed 2023 Medicare physician fee schedule would deepen physician pay cuts while expanding access to telemedicine, behavioral health care, and cancer screening. If implemented, it also would significantly modify the Medicare Shared Savings Program.

The Texas Medical Association is reviewing the proposed regulation and its impact in detail and will submit comments to the Centers for Medicare & Medicare Services (CMS) by its Sept. 6 deadline. But Keller pediatrician and Texas Medical Association President Gary W. Floyd, MD, says physician pay cuts threaten patients’ access to care, regardless of any expansion plans.

“A lot of our physicians who have Medicare practices can’t absorb this kind of cut anymore,” he said.

The 2,066-page proposal, which was released July 7, lowers the conversion factor that helps determine physician payments by 4.4% compared with the 2022 formula. If enacted, the proposed cut would be one of many to take effect in 2023, including a sequester cut and other reductions mandated by law, barring intervention by Congress.

After decades of incremental physician pay cuts, TMA has joined a chorus of state medical and national specialty societies calling for Medicare physician payment system reform.

“Bottom line, we need a total overhaul … of our Medicare payment system,” Dr. Floyd said.

The fee schedule proposal also aims to expand access to care, especially in rural and underserved areas, which CMS claims could help address health inequities as well as long-standing issues related to mental health, the opioid epidemic, and cancer treatment, according to a July 7 press release. 

On telehealth, CMS proposes to:

• Make several telehealth services available through 2023 that are temporarily available because of the federal COVID-19 public health emergency (PHE);
• Extend certain flexibilities for 151 days after the PHE ends, including allowing telehealth services to be provided with the Medicare patient located anywhere, such as in the patient’s home; via audio-only options; and by physical therapists, occupational therapists, speech-language pathologists, and audiologists; and
• Delay the in-person visit requirement for mental health services provided via telehealth until after the 151-day period.

Regarding behavioral health, CMS proposes to:

• Allow licensed professional counselors, marriage and family therapists, and other behavioral health practitioners to provide care under general, rather than direct, supervision;
• Pay clinical psychologists and clinical social workers to provide integrated behavioral health services as members of a patient’s primary care team;
• Bundle certain chronic pain management and treatment services into monthly payments; and
• Cover opioid treatment provided from mobile units, such as vans, which are more accessible to people who are homeless or live in rural areas.

For cancer screening, CMS proposes to:

• Consider a colonoscopy following an at-home test a preventive service, meaning cost-sharing would be waived for Medicare patients; and
• Cover colonoscopies for Medicare patients who are 45 or older.

The proposal also lays out plans to incorporate advanced shared savings payments to certain new Medicare Shared Savings Program accountable care organizations (ACOs), among other proposals to boost ACO participation. Those payments could be used to address Medicare patients’ nonmedical needs affecting their health.

As in previous years, the fee schedule proposal includes changes to Medicare’s Quality Payment Program (QPP) and the Merit-Based Incentive Payment System (MIPS). CMS says its proposals focus on MIPS Value Pathways (MVPs) – a new, optional reporting framework set to debut in the 2023 performance year – and limit adjustments to traditional MIPS in an effort to spur participation in MVPs.

As TMA continues to analyze the proposal, physicians can consult CMS’ fact sheets, which address the proposal in general as well as the QPP-related components.