Partnering for appropriate reimbursement

The letters to CMS were to address recently shared policy updates including (1) the calendar year 2023 Notice of Proposed Rule Making (Proposed Rule), (2) CMS-1772-P, the CY 2023 Centers for Medicare & Medicaid Services (CMS) update to the hospital outpatient prospective payment and ambulatory surgical center payment rules, and (3) CMS-1770-P, the revisions to Medicare payment policies under the Medicare Physician Payment Schedule and (3) Practice Expense Data Collection and Methodology.

CHEST and the American Thoracic Society joined to provide comments in response to the proposed Medicare Physician Fee Schedule for 2023. In this letter, the pulmonary associations highlight:

• Concern of CMS’s proposal to issue CY 2023 Medicare conversion factor (CF) of $33.0775, a decrease of $1.53 or 4.42 percent from the 2022 CF rate.

• A proposal to delay the new policy on split/shared billing that requires the provider who spent >50 percent of the time in the E/M service to be the billing provider until 2024.

• Request for Medicare reimbursement for potentially underutilized services including: pulmonary rehabilitation, advanced care planning, lung cancer screening, preventative vaccinations and liquid supplemental oxygen.

CHEST, the American Association of Cardiovascular and Pulmonary Rehabilitation (AACVPR) and other associations provide comments to CMS-1772-P, the CY 2023 Centers for Medicare & Medicaid Services (CMS) update to the hospital outpatient prospective payment and ambulatory surgical center payment rules calling for CMS to put a halt to the proposed 45% reduction in CY 2023. The letter recommended splitting the Level 1 Minor Procedures (APC 5731) group into two components: with one APC including codes costing more than $20.00 and the second APC including codes costing less than $20.00.

It also advocated for cardiac rehabilitation and pulmonary rehabilitation programs including that the decision on whether to provide direct supervision through the virtual presence of the physician via real-time, two-way audio/virtual telecommunications should be left up to the physician.

• Letter to CMS on CY 2023 HOPPS

• Letter to CMS on CY 2023 Physician Fee Schedule

• Letter to CMS on Practice Expense Survey Requirements

• Letter to CMS on Medicare Physician Fee Schedule for 2023