On July 7, the Centers for Medicare and Medicaid Services (CMS) issued the Medicare Physician Fee Schedule proposed rule for 2023, with policy changes that would reduce payments for radiation oncology (RO) services by approximately 4% next year. This reduction is due to the expiration of the 3% increase associated with the Protecting Medicare and American Farmers from Sequester Cuts Act, as well as the Medicare and CHIP Reauthorization Act statutory required update of 0%, and a budget neutrality adjustment of 1.55%. Additionally, 2023 marks the second year of the four-year phase in the Clinical Labor Price update which lowers payments to specialties that use expensive equipment, such as RO, in the budget neutral environment for practice expense. 

The proposed rule also includes several requests for information of interest to RO:

Strategies for Updates to Practice Expense (PE) Data Collection and Methodology

• With the goal of improving the information CMS uses in its PE methodology, CMS is requesting information on how it can improve the collection of PE data inputs and refine the PE methodology.

Medicare Parts A and B Payment for Dental Services

• Dental services are covered by Medicare in a limited number of circumstances, including when needed for some radiation therapy treatments. To provide greater clarity on the issue of dental coverage, CMS is proposing to clarify its interpretation and codify certain payment policies for medically necessary dental services. The Agency seeks input on types of clinical scenarios where dental services may be required for a covered service to succeed.

Medicare Potentially Underutilized Services

• CMS is concerned that there are high-value health services that that are being underutilized, especially in underserved communities, and is seeking comment on how to identify these services. Additionally, CMS seeks comment on how to improve access to these high-value services.

Strategies for Improving Global Surgical Package Valuation

• CMS wants to improve the payment accuracy for the global surgical packages under the MPFS and is seeking comments on strategies to do so.

In addition to these requests for information, the proposed rule contains several other proposals from CMS that would impact the RO community.

Determination of Malpractice (MP) Relative Value Units (RVUs)

• For CY 2023, CMS proposed to incorporate some refinements to its MP RVU calculation, including improving its imputation strategy to develop a more comprehensive data set and the creation of a risk index.

Rebasing and Revising the Medicare Economic Index

• The Medicare Economic Index (MEI) reflects the weighted-average annual price change for various inputs involved in furnishing physicians’ services and is used by CMS for various calculations that impact the MPFS. The Agency proposes to update the MEI cost weights to reflect more current market conditions.

Payment for Medicare Telehealth Services

• Some services were added to the Medicare Telehealth Services List on a temporary basis due to the COVID-19 PHE, and the proposed rule specifies which services will no longer be on the list 152 days after the end of the PHE (the statutorily-defined time period). This includes CPT Code 77427 Radiation Treatment Management.

ASTRO will submit comments to CMS later this summer. Read ASTRO’s detailed summary of the proposed rule for more.