Advocacy Alert: 2023 PFS and HOPPS Final Rules Released
Wednesday, November 2, 2022
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Posted by: ACRO
On November 1, 2022, the Centers for Medicare & Medicaid Services (CMS) released the 2023 Physician Fee Schedule (PFS) and Hospital Outpatient Prospective Payment System (HOPPS) Final Rules. While radiation oncology reimbursement once again was positive for services provided in the hospital outpatient setting, the PFS conversely once again was negative for freestanding radiation oncology. Due to ongoing cuts to the conversion factor and the so-called “clinical labor cuts,” freestanding radiation oncology will be subject to cuts of around 5% in 2023 if Congress does not act.
ACRO is aggressively advocating to the Hill for a reversal of these PFS cuts in end-of-year Medicare legislation.
Additionally, CMS notes the following in the 2023 PFS Final Rule: - On August 29, 2022, CMS finalized delaying the current start date of the Radiation Oncology Model (ROM) to a date to be determined through future rulemaking. In the CY 2020 PFS final rule (84 FR 62797), we finalized that, in the interest of payment stability, we would continue to maintain current coding for radiation treatment services, including HCPCS G-codes with their current work RVUs and direct PE inputs, given the introduction of the RO Model, and to prevent disruption in beneficiary access to radiation treatment services. While we did not make any proposals for payment for these radiation treatment services under the PFS for CY 2023, we note that we are reviewing our current coding and payment policies for the radiation therapy services, including whether we should adopt the revised CPT coding that was established in CY 2015 to allow for coding and payment consistency, considering the fact that CMS finalized delaying the current start date of the ROM earlier this year. Any such changes would be addressed in future rulemaking.
In the August regulation to delay the RO Model, CMS noted “some interested parties will not support the RO Model test moving forward with unchanged discounts and as noted previously, these interested parties have also requested that we not increase the geographic scope of the Model.” ACRO has been willing to explore a larger geographic scope if CMS would consider a lower discount for the RO Model, for which ACRO has consistently advocated. ACRO will continue to work with CMMI in 2023 on acceptable paths forward on the RO model.
Please also visit acro.org for additional news.
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