Podiatry Coding & Billing Alert

CF cuts will affect all specialties.

The Centers for Medicare & Medicaid Services (CMS) issued the final rule for calendar year (CY) 2023, and you should prepare yourself for some changes affecting podiatry.

Wondering which updates will affect podiatry practices the most, both positively and negatively? How will the annual change to the conversion factor impact your bottom line?

Read on and find out.

Budget CF Reduction Into Your Bottom Line

The least popular of CMS’ final proposals for 2023 involves a reduction to the conversion factor (CF), and providers in the healthcare industry aren’t happy with the new cuts. While many continue recovering from the aftermath of the pandemic and skyrocketing inflation, they hoped CMS wouldn’t reduce its CF as initially proposed after members of the healthcare industry expressed their concerns.

However, CMS reduced it even more — their proposal last July had suggested a reimbursement cut from $34.61 to $33.08 for CY 2023, but they reduced it further to $33.06 — a total of 4.5 percent overall. Fortunately, CMS estimates the impact on podiatry for the total allowed charges should be less severe — a 2 percent reduction for non-facility charges and 0 percent for facility charges, making the total impact estimated at 1 percent.

Ask Congress to Act

The American Medical Association (AMA) spoke out about the cuts, noting that providers are already struggling, and the CF cut would “create immediate financial instability in the Medicare physician payment system,” according to AMA President Jack Resneck Jr., MD. “Unless Congress acts by the end of the year, physician Medicare payments are planned to be cut by nearly 8.5 percent in 2023 — partly from the 4 percent PAYGO sequester — which would severely impede patient access to care due to the forced closure of physician practices and put further strain on those that remained open during the pandemic” (https://www.ama-assn.org/press-center/press-releases/ama-fee-schedule-reminds-congress-cuts-threaten-patient-access).

Consequently, many provider advocacy groups are pushing for Congress to intervene, including the American Podiatric Medical Association (APMA). It urges all podiatry practitioners to use APMA eAdvocacy (https://apma.quorum. us/signup/) to ask Congress to act and cancel or delay the Medicare reimbursement cuts, not only because of the impact on a practice’s bottom line, but also because it will impact patient outcomes.

“Ninety percent of medical practices reported that the projected reduction to the 2023 Medicare payment would reduce access to care,” according to Anders Gilberg, Medical Group Management Association (MGMA) senior vice president, Government Affairs. Additionally, “there are claims processing implications for retroactively applying these policies,” Gilberg notes (https://www.mgma.com/news-insights/press/november-1,-2022-mgma-statement-on-cms-final-2023).

Consider Social Factors and Barriers to Care

The 2023 final rule also continues CMS’ attempts to encourage providers to incorporate social factors into patient care. “Patients’ social drivers of health can be a key component to a patient achieving health equity within all clinical settings and clinician types. Improving the clinician’s understanding of the social obstacles their patients face can provide critical insight into predicting negative health outcomes and improving a patient’s health status,” according to the final rule.

This initiative affects all specialties, including podiatry. For example, a diabetic patient’s financial status might prevent them from adhering to their recommended diet, since sugary foods and carbohydrates are often the cheapest diet options. So, podiatrists could reinforce and document the nutritional information the patient is getting from their primary care physician (PCP) to help minimize adverse effects from hyperglycemia on problems like diabetic foot ulcers.

Patients may also not be able to afford orthopedic or appropriate footwear, so podiatrists should recommend budget alternatives or work with patients on payment programs for orthotics. All of these can be pertinent to podiatry practices and affect patient outcomes, and there are many new ICD-10-CM codes you can use to document these situations.

Delay Renaming of Skin Substitutes

In some good news for podiatrists, for the time being, the CMS plan to rename “skin substitutes” to “wound care management products” and the overhaul of the nomenclature, coding, and payment of cellular and/or tissue-based products (CTP) is on hold pending a town hall early next year to address concerns over the proposed change.

This follows APMA’s recommendation that “CMS adopt the term ‘Cellular and/or Tissue Based Products for Skin Wounds’ or CTPs, in order to create less confusion and to utilize a more accurate term describing the entire suite of products currently marketed as well as prospective ones,” according to a letter in response to CMS’ proposed changes for 2023 (https://www.apma.org/News/NewsDetail.cfm?ItemNumber=51689).

Prepare Yourself for More E/M Changes

CMS also finalized several changes in coding and documentation for “Other E/M visits,” which include hospital inpatient, nursing facility, and home or residence services, effective Jan. 1, 2023. Those evaluation and management (E/M) changes justify a full article, which will appear in the next Podiatry Coding & Billing Alert.

Read the full report at the Federal Register: (https://www.federalregister.gov/documents/2022/11/18/2022-23873/medicare-and-medicaid-programs-cy-2023-payment-policies-under-the-physician-fee-schedule-and-other)