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A Harsh Proposal to Medicare Reimbursement: Take Action Now

On July 7, 2022, the Centers for Medicare & Medicaid Services (CMS) released its more than 2,000-page Medicare Physician Fee Schedule (PFS) and Quality Payment (QPP) proposed rule for Calendar Year 2023. The top policy proposals impacting practices include:

Updating the annual conversion factor

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Making changes to Medicare telehealth

Extending flexibilities for billing Evaluation and Management (E/M) split (or shared) visits in 2023

Introducing new Merit-based Incentive Payment System (MIPS) Value Pathways, and;

Establishing changes to the Medicare Shared Savings Program

Focusing on the Medicare Physician Fee Schedule (PFS) Proposed Rule addressing Medicare Part B payments for physicians in 2023, the PFS conversion factor would be $33.08, a 4.4% decrease (-$1.53) from the CY 2022 PFS conversion factor of $34.61. But the changes do not end there.

Due to statutory factors, the rate would also be impacted by the 2% sequestration payment reduction currently suspended through the end of 2022 because of the public health emergency (PHE) declaration, and the additional 4% in what is called the “PAY-GO” rules—a rule designed to encourage Congress to offset the cost of any legislation that increases spending on entitlement programs or reduces revenues, so it does not expand the deficit. Physicians are potentially facing an up to 10.4% cut to reimbursement, making it untenable for many.

While these policies are only proposals at this time, they can be changed in the final PFS, which is usually released on or around November 1 each year. This ongoing trend of decreasing payments and significant cuts is a serious concern. Generally, Congress will implement last-minute changes while finalizing budget bills in December to help mitigate the cuts before they go into effect on the 1st of the year. But this process is not ideal, and more permanent solutions in Congress are needed.

CMS is collecting comments on the proposed rule until September 6, 2022. Comments submitted to CMS can have a significant impact on a proposed rule before it
is finalized.

Please take a moment to submit your comments at and enter CMS-1770-P in the Search section to be directed to the comment submission page.

CMS Proposed Rule Fact Sheet:   

Gabriela Villanueva is CAP’s Government and External Affairs Analyst. Questions or comments related to this article should be directed to