2023 Medicare Physician Fee Schedule Proposed Rule
Recently, the Centers for Medicare & Medicaid Services (CMS) released the CY 2023 revisions to payment policies under the Medicare Physician Fee Schedule (MPFS) and other changes to the proposed rule for Medicare part B payment policies (CMS-1770-P). In this article, we shared the impact of the 2023 MPFS proposed rule on neurology billing. The key points are as follows:
Impact of 2023 MPFS Proposed Rule on Neurology Billing
- CMS shows the impact of the provisions of the rule to be a zero percent chance for neurosurgery. However, CMS proposes a CY 2023 conversion factor (CF) of 33.0775, which is a 4.42 percent (rounded to 4.5%) reduction relative to the CY 2022 CF of 34.6062, which comes in addition to the pending 4% pay-as-you-go cut that congress postponed last year and the resumption of the 2% annual Medicare payment sequester.
- CMS received a request to designate CPT code 23091 (Allograft, structural, for spine surgery only) as potentially misvalued. CMS has disagreed with the rationale provided by the requester and is proposing not to designate the procedure as misvalued.
- CMS is considering proposals to rebase and revise the Medicare Economic Index (MEI) cost share weights, and the agency is soliciting comments on this issue. The MEI measures the input prices for providing physician services. The agency proposes a new methodology that allows data to reflect better current market conditions for both ‘physician ownership practices’ and self-employed physicians. It will also enable the MEI to be updated more frequently. The change would not impact the overall MPFS spending but could result in significant changes to payment for particular specialties. CMS is not proposing to use the updated MEI data to set payment rates for CY 2023 but is soliciting comments on future use.
- According to the analysis of the proposed rule by the American Association of Neurological Surgeons (AANS) and Congress of Neurological Surgeons (CNS), the estimated impact on neurosurgery if CMS were to use the proposed rebased and revised MEI cost share weights to adjust the RVUs would be an 8 percent decrease in total allowed charges.
- CMS is proposing to remove 125 minutes of equipment time for an exam light for spine CPT codes 63020 and 63030 because the RUC contested the typicality of its use to assess the wound and remove staples. However, this is standard equipment in neurosurgical and orthopedic exam rooms.
- CY 2022 was the final year of a multi-year phased update for practice expense (PE) for supplies and equipment and the first year of a four-year phase-in to update PE clinical labor pricing, as previous data for this component was nearly 20 years old. FY 2023 will be the second of the four years for the phased-in update, and CMS is soliciting comments on any concerns about the implementation process.
- CMS seeks public comment on strategies for ‘improving’ global surgery code values, continuing to assert that RVUs for these services are inaccurate.
- As part of the ongoing updates to E&M visits and related coding guidelines, CMS will adopt a substantial portion of the AMA CPT Editorial Panel-approved revised coding and updated guidelines for other E&M visits. This includes inpatient, observation, emergency department, nursing facility, and home/residence service visits.
- CMS is postponing its proposal for ‘split or shared’ E&M visits, defined as visits provided in a facility by a physician and a non-physician provider in the same group. Last year, CMS implemented a condition that only the practitioner who provides the substantive portion by the time of the visit would be able to bill for the visit. This rule proposes to delay 2024 the change until clinicians who furnish split (or shared) visits will continue to have a choice of history, physical exam, medical decision-making, or time spent to define the substantive portion, instead of using the only total time to determine the substantive portion.
- As part of an initiative begun in 2021 to sunset outdated National Coverage Determinations (NCDs), CMS has proposed discontinuing the NCD for Ambulatory Electroencephalographic Monitoring and has asked for public comment on the issue.
- CMS is not proposing to add CPT codes 95976 and 95977 (analysis of cranial nerve neurostimulation) to the Medicare telehealth services list because the full scope of service elements described by these codes cannot currently be furnished via two-way, audio-video communication technology. However, for potential future rulemaking, CMS will consider additional evidence regarding the ability to provide these services via telehealth, such as information indicating that current technology has evolved.
- CMS proposes to add CPT codes 95970, 95983, and 95984 (general brain nerve neurostimulation) to the Medicare telehealth services list on a Category 3 basis while soliciting comments on concerns regarding patient safety and whether the services are appropriate for inclusion outside the circumstances of the public health emergency (PHE).
The proposed rule on neurology billing for 2023 MPFS might bring changes affecting how neurology services are billed and reimbursed. Neurology practitioners should stay updated to adapt their billing practices accordingly for optimal reimbursement.
Most Common Neurology CPT Codes
Below are explanations for selected CPT codes related to specialized brain surgeries and procedures on the skull, meninges, and brain
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61796: Stereotactic radiosurgery
(particle beam, gamma ray, or linear accelerator): This code refers to a highly precise form of radiation therapy used to treat brain tumors and other neurological conditions. It involves delivering a focused radiation beam to the target area within the brain while minimizing exposure to surrounding healthy tissue.
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61797: Stereotactic radiosurgery
(particle beam, gamma ray, or linear accelerator): Similar to the previous code, this one also denotes stereotactic radiosurgery, which utilizes advanced technology to deliver radiation therapy with pinpoint accuracy. It’s often used for treating tumors and abnormalities in the brain without the need for traditional surgery.
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61798: Stereotactic radiosurgery
(particle beam, gamma ray, or linear accelerator): This code represents another instance of stereotactic radiosurgery, which can employ various types of radiation beams such as particle beams, gamma rays, or a linear accelerator. The choice of radiation modality depends on factors like the size and location of the lesion being treated.
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61799: Stereotactic radiosurgery
(particle beam, gamma ray, or linear accelerator): This code pertains to the specialized stereotactic radiosurgery technique, which offers a non-invasive alternative to traditional surgery for certain brain conditions. It’s characterized by its ability to precisely target tumors or lesions with high doses of radiation while sparing surrounding healthy tissue.
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61800: Stereotactic Radiosurgery (Cranial) Procedures on the Skull, Meninges, and Brain:
This code encompasses a range of stereotactic radiosurgery procedures tailored explicitly for conditions affecting the skull, meninges (protective membranes surrounding the brain and spinal cord), and brain. It highlights the versatility of stereotactic radiosurgery in addressing various neurological issues.
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61850: Neurostimulators (Intracranial) Procedures on the Skull, Meninges, and Brain:
This code denotes procedures involving the implantation or management of neurostimulator devices within the intracranial space, which can include deep brain stimulation (DBS) for treating movement disorders or other neurostimulation therapies for conditions like epilepsy or chronic pain.
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61860: Neurostimulators (Intracranial) Procedures on the Skull, Meninges, and Brain:
Similar to the previous code, this one also pertains to neurostimulator procedures within the intracranial region. These procedures often involve the implantation of devices that deliver electrical impulses to specific areas of the brain or nervous system to modulate neural activity and alleviate symptoms.
Medical Billers and Coders (MBC) is a leading medical billing company providing complete billing and coding services. To understand the impact of the 2023 MPFS proposed rule on neurology billing, we referred to an analysis done by the American Association of Neurological Surgeons (AANS) and Congress of Neurological Surgeons (CNS). Providers are advised to refer to the 2023 MPFS proposed rule and various fact sheets for detailed understanding. If you need neurology billing and coding assistance, email us at info@medicalbillersandcoders.com or call 888-357-3226.
FAQs
1. How does the 2023 MPFS Proposed Rule affect the conversion factor for neurology billing?
The Centers for Medicare & Medicaid Services (CMS) proposed a 2023 conversion factor (CF) of 33.0775, representing a 4.5% reduction from the 2022 CF of 34.6062. This adjustment impacts payment rates, as a lower CF could result in decreased reimbursement for neurology services.
2. How might the Medicare Economic Index (MEI) changes affect neurology billing?
CMS is considering revising the Medicare Economic Index (MEI) cost share weights to reflect current market conditions better. While the proposed rule does not use this updated MEI data to set 2023 payment rates, it could lead to significant adjustments in future reimbursement for specific specialties, including neurology.
3. Are there changes to equipment time for specific neurology-related CPT codes in the 2023 MPFS Proposed Rule?
Yes, CMS proposes removing 125 minutes of equipment time for an exam light associated with spine CPT codes 63020 and 63030, which may alter the practice expense calculation for these procedures. This change arose from a recommendation by the RUC, which questioned the necessity of the equipment use in these specific procedures.
4. Will neurology-related E&M visit codes be affected by the 2023 MPFS Proposed Rule?
Yes, CMS plans to adopt new coding guidelines for E&M visits, including inpatient, observation, and emergency department visits. These updates align with changes approved by the AMA’s CPT Editorial Panel and may streamline the billing process for E&M services, although practitioners should review how these updates impact billing practices.
5. Are any neurostimulation or neurosurgery codes being added to the Medicare telehealth services list?
CMS proposes adding neurostimulation codes 95970, 95983, and 95984 to the Medicare telehealth services list on a Category 3 basis. This temporary addition allows these services to be provided via telehealth during a public health emergency (PHE), but CMS seeks comments on their continued inclusion beyond the PHE.
Reference: CMS Proposes Physician Payment Rule Expand Access to High-Quality Care
