In comments submitted to the Centers for Medicare and Medicaid Services (CMS) in response to the CY 2023 Medicare Physician Fee Schedule and Quality Payment Program proposed rule, the American College of Rheumatology (ACR) applauded proposals that would provide more flexibility and improve care coordination, while raising concerns about proposed cuts to reimbursement for critical services provided by rheumatologists and other cognitive specialists.

“The ACR commends the Centers for Medicare and Medicaid Services (CMS) for its continued recognition of the value of complex medical decision-making provided by rheumatologists and other cognitive care specialists in the treatment of their patients. However, we fear the significant harm that the decreased conversion factor will have on our rheumatology-care team and our patients while they continue to recover from the stress of the past two years,” said Kenneth Saag, MD, MSc, President of the ACR, referencing provisions in the proposed rule that would continue to operationalize and fine-tune the Evaluation and Management (E/M) code revaluation and documentation requirements.

The ACR’s main comments and concerns are outlined as follows:

Conversion Factor Decrease That Would Set Back Pandemic Recovery

CMS has proposed decreasing the CY2023 conversion factor from $34.61 to $33.08, a 4.4% decrease that would prove detrimental to the stability of rheumatology providers. In the second year of a public health emergency and facing staggering inflation costs and a significant workforce shortage, rheumatologists struggle to continue providing care for their patients. The ACR strongly urges CMS not to move forward with this adjusted conversion factor, which would have a damaging impact on an already strained system that is still working to recover from the pandemic.

Musculoskeletal Ultrasound is a Valuable Diagnostic Tool – Cutting Its Reimbursement Will Hurt Patient Access to Care

ACR strongly opposes these drastic proposed cuts and urges CMS not to proceed. Arbitrarily reducing the work required to appropriately perform and interpret musculoskeletal ultrasound is not justified and devalues the work of the AMA and specialty societies involved in the process. Instead, CMS must maintain the pre- and post-time and allow for greater stakeholder engagement in determining the appropriate practice expenses to allow accurate reimbursement for this important diagnostic service.

Split/Shared Services – Agree with CMS to Delay

In the CY 2022 PFS final rule, CMS finalized a policy allowing payment where a physician and non-physician providers (NPP) deliver service together for a split/shared facility-based visit (including prolonged visits). This called for the provider to deliver more than half of the care provided during a shared/split visit to bill for the services, which did not consider the role of medical decision-making as a primary determining factor in the successful outcome of the visit and raises concerns about negative implications on collaborative care and the critical role of medical decision-making in patient care.

The ACR supports CMS’s proposal to delay the split/shared visit policy and extend flexibilities to permit split/shared E/M visits to be billed based on one of three components (history, exam, or medical decision making) or time until 2024, allowing physicians and NPPs to establish a more collaborative cadence in their visits that emphasizes the cognitive skills needed to provide the best care for their patients.

“Our nation’s healthcare system continues to navigate the challenges of a global pandemic that has strained resources and providers,” noted Saag. “We appreciate the policies and flexibilities set forth by CMS to help alleviate these challenges and the agency’s attention to the concerns outlined by the rheumatology provider community while we all work to provide top quality patient care.”

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