AUA Comments to CMS on 2023 Proposed Medicare Physician Fee Schedule

On July 7, the Centers for Medicare & Medicaid Services (CMS) released the Medicare Physician Fee Schedule (MPFS) proposed rule for CY 2023 (CMS-1770-P). This rule updates payment policies and payment rates for Part B services furnished under the MPFS, as well as makes changes to the Quality Payment Program (QPP). The AUA submitted comments on the proposed rule on September 1.

Related: View the AUA’s Summary on the proposed rule for the CY 2023 Medicare Physician Fee Schedule.

AUA’s comment letter specifically addresses the following:

  • Conversion Factor Update
  • Proposed Valuation of Urology-Specific Codes for CY 2023
  • Evaluation and Management (E/M) Services
  • Payment for Medicare Telehealth Services
  • Requiring Manufacturers of Certain Single-dose Container or Single-use Package Drugs to Provide Refunds with Respect to Discarded Amounts
  • Strategies for Improving Global Surgical Package Valuation
  • Rebasing and Revising the Medicare Economic Index (MEI)
  • Strategies for Updates to Practice Expense Data Collection and Methodology
  • Medicare Potentially Underutilized Services
  • Merit-Based Incentive Payment System (MIPS) Value Pathways (MVPs)
  • Request for Information: Health Equity Measures

The AUA placed particular emphasis on CMS’ proposed valuation of urology-specific codes for Percutaneous Nephrolithotomy (PCNL) CPT codes (50080 and 50081), urging CMS to finalize the RUC-proposed values as it maintains the relativity of the procedures and accounts for the time, mental effort, and skill associated with the codes.

The AUA urged CMS to finalize a policy that will permanently implement telehealth provisions, including virtual direct supervision, audio-only services and pay parity for reimbursement to be given at the facility rate, beyond the end of the Public Health Emergency (PHE), recommended CMS finalize changes to the inpatient and outpatient observation code set for Evaluation & Management services, urged CMS to finalize a policy that raises the applicable percentage for refunds with respect to discarded drug amounts, and submitted comments on CMS’s proposals with respect to the Medicare Economic Index, Practice Expense Data Collection and Methodology, the Quality Payment Program and MIPS Value Pathways (MVPs).