ACC Submits Formal Comments to CMS on CY2023 Medicare Physician Fee Schedule

The ACC on Sept. 3 submitted formal comments to the Centers for Medicare and Medicaid Services (CMS) regarding the 2023 Medicare Physician Fee Schedule (PFS) Proposed Rule, which, among other items of importance to cardiovascular clinicians, includes egregious cuts to reimbursement for cardiac ablation services.

The formal comments focus primarily on CMS’ proposed changes to work relative value units (RVUs) which are well below the recommendations of the Relative Value Scale Update Committee (RUC). Since the release of the proposed rule, ACC staff and member leadership has been working tirelessly – often in conjunction with partner cardiovascular societies – to combat these significant reductions in service value.

A large-scale grassroots campaign in close collaboration with the Heart Rhythm Society (HRS) has resulted in hundreds of emails to CMS from clinicians across the U.S., helping to amplify these efforts. Additionally, nearly a dozen meetings have been held with members of Congress and/or their staff to enlist their help to stave off these cuts. The College has also met with CMS staff directly to fully explain ACC’s concerns. The ACC and the Society of Cardiovascular Angiography and Interventions have also come together to oppose the CMS proposed reductions to the endovascular pulmonary arterial revascularization and pulmonary angiography code sets, also below RUC values.

Outside of the reductions in cardiovascular services, the letter also addressed the following provisions included in the proposed rule:

  • Support for the continuation of direct supervision of cardiac rehabilitation being allowed via real-time audio-visual telecommunication technology following the Public Health Emergency (PHE). This allowance is currently set to expire 151 days after the end of the PHE.
  • Support for the delay of removing medical decision making (MDM) as a factor to determine billing of split-shared E/M codes; with comment that MDM should be reinstated as a determining factor going forward. As proposed, this change would take effect in 2024 and redefine the definition of substantive portion as more than half of the total time.
  • Request to delay proposed changes to the Medicare Economic Index, which would have shifted resources away from physician payment towards practice expense and other non-physician payment costs until additional data is available – specifically the American Medical Association’s upcoming Physician Practice Information Survey.
  • Support for proposed expansion of dental care to improve care of cardiac valve patients.
  • Support for proposed advanced payments under the Shared Savings Program to Accountable Care Organizations (ACOs) in underserved areas/communities as well as expansion of ACO eligibility criteria to allow lower revenue ACOs to participate.
  • Support for additional quality measures to the Advancing Care for Heart Disease MVP, with the exception of Preventative Care and Screening: Screening for Depression and Follow-Up Plan, and Risk-Standardized Acute Unplanned Cardiovascular-Related Admission Rates for Patients with Heart Failure. ACC also continues to have concerns with costs measures.
  • Comments in response to CMS’s request for information to evaluate and implement initiatives in reducing disparities, particularly in measuring healthcare disparities and future efforts in reducing disparities.

You can read the ACC’s full comment letter here. The 2023 Medicare Physician Fee Schedule proposed rule can be found here. Additional information on the rule can be found in the CMS Press Release, MPFS Fact Sheet, Shared Savings Fact Sheet, and QPP Fact Sheets. CMS will issue a final rule notice by Nov. 2.

Before the final rule is issued, ACC members can join their colleagues in Washington, DC, for the 2022 ACC Legislative Conference on Oct. 16-18. Attendees will learn more about select items in the PFS along with other important health policy issues. Register here.

Clinical Topics: Cardiovascular Care Team, Diabetes and Cardiometabolic Disease, Geriatric Cardiology, Heart Failure and Cardiomyopathies, Invasive Cardiovascular Angiography and Intervention, Prevention, Pulmonary Hypertension and Venous Thromboembolism, Vascular Medicine, Acute Heart Failure, Pulmonary Hypertension, Interventions and Imaging, Interventions and Vascular Medicine, Angiography, Nuclear Imaging, Hypertension

Keywords: Medicare Part B, Technology, Dental Care, Angiography, Heart Failure, Heart Diseases, Heart Valves, Clinical Decision-Making, Health Policy, Physicians, Fee Schedules, Quality Indicators, Health Care, Public Health, Medically Underserved Area, Leadership, Hypertension, Pulmonary, Healthcare Disparities, Follow-Up Studies, Electronic Mail, Depression, Cardiac Rehabilitation, American Medical Association, Accountable Care Organizations, Centers for Medicare and Medicaid Services, U.S., Aged

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