The 2023 Medicare Physician Fee Schedule Proposed Rule is Out

November 28, 2022

The 2023 Medicare Physician Fee Schedule (CMS-1770-P) went on display late afternoon July 7, 2023.

Sweeping changes are proposed for cellular and/or tissue-based products (CTPs) when applied in the physician’s office – more on that later. In the meantime, here are some other proposed changes that might be overshadowed by the changes to office based CTP use:

Conversion Factor

CMS has proposed a Calendar Year (CY) 2023 physician conversion factor of $33.0775. This represents a 4.4% reduction from the 2022 physician conversion factor of $34.6062. Additionally, changes to several evaluation and management (E/M) code families are expected to result in an additional reduction of about 1.5% to the 2023 Medicare conversion factor due to statutory budget neutrality requirements.

Split/Shared Visits

CMS is proposing to maintain the 2022 definition of the “substantive portion” of an E/M service performed by both a physician and a non-physician practitioner in a facility setting through 2023. Clinicians who furnish the split/shared visit will continue to have a choice of history, physical exam, medical decision making, or more than half of the total practitioner time spent to define the substantive portion to determine which practitioner will bill the visit.

Evaluation and Management Services

As part of the ongoing updates to E/M visits and related coding guidelines, the American Medical Association (AMA) CPT Editorial Panel approved revised coding and updated guidelines for Other (hospital inpatient, hospital observation, emergency department, nursing facility, home or residence services, and cognitive impairment assessment) E/M visits, effective January 1, 2023. CMS is proposing to adopt most of these changes effective January 1, 2023, including:

  • New descriptor times (where relevant)
  • Revised interpretive guidelines for levels of medical decision making
  • Choice of medical decision making or time to select code level (with several exceptions)
  • Eliminated use of history and exam to determine code level

Stay tuned for more information on the 2023 proposed rule.

Caroline Fife, MD

Dr. Fife is Co-Founder and Chief Medical Officer of Intellicure, Executive Director of the US Wound Registry, and Editor of Today’s Wound Clinic.

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