Have you seen the 2023 Medicare Physician Fee Schedule Proposed Rule? The rule brought up policy changes for Medicare Part B Payments. CMS has shared detailed information on its official websites. Apart from revisions in payment policies, the rule contains other changes as well. Either the rules apply to certain specialties specifically or may impact them differently. That’s why it’s important to analyze the MPFS 2023 rules. To keep things easy to comprehend, QPP MIPS has shared some proposed changes for neurology billing services.
Here, we will have a quick look at the proposed changes to neurology practices. Let’s just dig in without delay!
MPFS 2023 Propose Rule: What’s the Plan for Neurology Billing Services?
Neurology billing services are a little complicated and require more attention than others. As a medical billing services company, we provide neurology billing and coding services to neurologists. That’s why we are aware of all the intricacies and prefer to stay abreast of changes to improve RCM. Our expert medical billing and coding specialists have given close consideration to the MPFS’s proposed rule. And here is what they have gathered for all neurology practices.
Let’s see what information the 2023 proposed rule encloses for neurology billing services!
Proposed Assessment of PFS 2023 for Neurosurgery
There are several provisions regarding neurosurgery, however, there is no anticipated impact. Notably, CMS has given a new conversion factor (CF) of 33.0775 for CY 2023. This CF differs from what was finalized for CY 2022 (34.6062). We can observe an approximately 4.42% reduction in CF for the neurology billing services.
Pay-as-you-go is another addition to the neurology payment policies, postponed until CY 2022. Anyhow, in the 2023 proposed rule, Congress has included it at a rate of 4%. Additionally, the rule proposes the reinstatement of the 2% annual Medicare payment sequester.
CPT Code Designation and Misvaluation
CPT code 23091 is for allograft, structural, and spine surgery only. The Centers for Medicare and Medicaid Services got a request against this code. The requester desired to classify this code and potentially misvalued it. CMS looked closely at their request but still decided not to accept this rationale. So, as per CMS’s proposal in PFS 2023, there is nothing wrong with the code. That’s why there is no need to designate it as misvalued.
Revamping the Medicare Economic Index (MEI)
CMS is thinking about updating and rebasing the MEI cost-sharing weights. Additionally, it is asking for feedback on this subject. The MEI measures the cost of physician services as an input. The CMS plans to use a novel approach. It must better reflect the current state of the market for both “physician ownership practices” and solo practitioners. While this change does not affect total MPFS spending, it may have a significant impact on payments for individual specializations. The suggested MEI data is not intended for payment rate setting in CY 2023. CMS, on the other hand, is looking for insights for future use.
Projected Impact on Neurosurgery
The American Association of Neurological Surgeons (AANS) and Congress of Neurological Surgeons (CNS) have deeply analyzed the payment policy changes. They have showcased the influence of rebased and revised MEI cost share weights for RVU adjustment. According to them, if CMS implements this policy, neurosurgeons will see their total allowed charges reduced by 8%.
Equipment Time Adjustment
CMS plans to eliminate 125 minutes of equipment time for an exam light in the spine CPT codes 63020 and 63030. This proposal has generated debate. The RUC argued against the device’s common use for wound evaluation and staple removal. However, neurosurgery and orthopedic exam rooms already come with this technology.
Progress in the Practice Expense (PE) Update
Back in CY 2022, CMS ruled out the multi-layered phased update for practice expenses (PE). At the same time, it has implemented a four-year phase-in to update PE clinical labor pricing. The earlier data for this component was nearly two decades old. In FY 2023, the phased-in update continues into its second year. Again, CMS is inviting feedback regarding any concerns about the implementation process.
Global Surgery Code Values Enhancement
CMS continues to claim that RVUs for these services are incorrect for neurology billing services. Anyhow, it is asking for feedback on possible methods for “improving” global surgical code values.
Advancements in E&M Visits and Coding Guidelines
Congress is still making modifications to the coding standards that apply to E&M visits. Therefore, it will mostly implement the new rules and revised coding that was authorized by the AMA CPT Editorial Panel. All inpatient, observational, emergency department, nursing home, and home/residence service visits are included in this.
Postponement of the ‘Split or Shared’ E&M Visits Proposal
CMS has deferred the proposal for ‘split or shared’ E&M visits as well. It covers visits provided by a physician and a non-physician provider within the same facility. This rule initially stipulated that only the physicians contributing the substantive portion could bill for the visit. Anyhow, it will now be detained until 2024. Clinicians offering split (or shared) visits will retain their rights, such as:
- Choice of history,
- Physical exam,
- Medical decision-making, or
- Time spent to define the substantive portion, etc.
Sunsetting Outdated National Coverage Determinations (NCDs)
Also, CMS is proposing to discontinue the NCD for Ambulatory Electroencephalographic Monitoring. This is part of an ongoing initiative to phase out outdated National Coverage Determinations (NCDs). Moreover, CMS has asked for public comment on this matter too.
Telehealth Services Inclusion
CMS opposes the addition of CPT codes 95976 and 95977 to the Medicare telehealth services list. These codes are for the analysis of cranial nerve neurostimulation. CMS’s decision not to do so is justifiable. Current two-way audio-video communication technology, according to CMS, is incompatible with it. Thereby, the complete extent of service aspects outlined in these codes cannot yet be supported. If technology advances to provide these services via telehealth, CMS is still willing to take more data into account for potential rulemaking in the future.
Conversely, CMS intends to add CPT codes 95970, 95983, and 95984. They are suggested to be added to the telehealth services list under Category 3. These codes are for general brain nerve neurostimulation. Comments are welcome regarding concerns about patient safety. Also, CMS wants feedback on the suitability of these services outside the context of PHE.
Conclusion
QPP MIPS is a major provider of neurology billing services for comprehensive medical billing and coding services. Providers are urged to read the 2023 MPFS proposed rule and other fact sheets as well. It will give them a thorough understanding of how the proposed rule would affect neurology billing services.
