Radiology Coding Alert

Read what radiology subspecialties have to say about the CF.

On Nov. 18, 2022, the Centers for Medicare & Medicaid Services (CMS) issued its calendar year (CY) 2023 Medicare Physician Fee Schedule (MPFS) final rule, and radiology practices have reacted to the adjusted conversion factor (CF) news. After the announcement of a proposed decreased CF, how did Medicare adjust the CF following stakeholders’ feedback?

Understand how the CY 2023 MPFS final rule affects your practice’s bottom line.

Learn How a Larger CF Decrease Affects Your Practice

In a move that has garnered quite a backlash from stakeholders, CMS finalized a CF of $33.0607, which is a 4.5 percent decrease from the CY 2022 MPFS final rule. The finalized CF decrease is also larger than the 4.4 percent decrease proposed in July 2022. The agency came to the finalized CF by taking the CY 2022 CF “without the 1-year 3.00 percent payment increase provided by the Protecting Medicare and American Farmers from Sequesters Cuts Act” and multiplying it by the -1.60 percent budget neutrality (BN) adjustment.

The CY 2022 final rule afforded a temporary 3 percent increase in PFS payments, but that increase expired at the end of 2022, which is why CMS didn’t factor the number into the CY 2023 CF. “The expiration of this 3.00 percent payment supplement to payment amounts will result in the CY 2023 conversion factor being calculated as though the 3.00 percent payment supplement for the CY 2022 conversion factor had never been applied,” CMS writes. At the same time, BN adjustments are required by law to balance the increased spending caused by proposals to increase relative value units (RVUs) in the MPFS.

As a result of the larger CF decrease, negative BN adjustment, and missing temporary payment increases, radiology practices are facing lower reimbursement for 2023. According to the CY 2023 MPFS final rule, the overall payment changes for radiology specialties are as follows:

While the payment reductions are less than those originally put forward in the CY 2023 MPFS proposed rule, specialty societies and radiology practices were upset by the news.

Don’t Give Up: Societies Urge Congress to Act

The American Society for Radiation Oncology (ASTRO) expressed their thoughts about the 2023 cuts to radiation oncology services in their summary of the final rule: “This additional cut adds to year-over-year reductions that will prevent radiation oncology practices from investing in the latest technologies for treatment delivery and jeopardize access to care for cancer patients” (www.astro.org/ASTRO/media/ASTRO/Advocacy/PDFs/2023MPFS_FinalRuleSummary.pdf).

Similarly, the American College of Radiology (ACR) wrote in their summary of the CY 2023 MPFS final rule, “If Congress does not intervene to extend the 3 percent increase provided by the Protecting Medicare and American Farmers from Sequester Cuts Act, the percent decreases mentioned above will be greater for CY 2023” (www.acr.org/-/media/ACR/Files/Advocacy/MPFS/2023-MPFS-FR-ACR-Detailed-Summary-FINAL-111822.pdf).

If Congress doesn’t extend the temporary 3 percent increase into 2023, the American Medical Association (AMA) estimates the total decreases to cut even deeper for the specialties:

• Radiology: 5 percent decrease
• Interventional radiology: 6 percent decrease
• Nuclear medicine: 5 percent decrease
• Radiation oncology: 4 percent decrease
• Radiation therapy centers: 4 percent decrease

Congress could intervene before the end of 2022 and adjust the CF, as they did in 2021 at the last minute, but that had not occurred as of publication time. “To avoid significant disruptions in patient access to care, Congress must act before the end of the year to mitigate the scheduled payment reductions,” according to a Nov. 14, 2022, open letter to U.S. Congressional and Senate leaders signed by 24 specialty societies, which includes the ACR, ASTRO, American College of Radiation Oncology, and the Society of Interventional Radiology (www.acr.org/-/media/ACR/Files/Advocacy/AIA/CLC_Year-End-Priorities_FINAL_111722.pdf).

However, until that reprieve happens, practices will be preparing for a more costly 2023 that could impact care delivery.

Understand Which Imaging Services Are Receiving Revised Values

Despite the unfortunate news of the decreased CF, the CY 2023 MPFS final rule did provide good news for the valuation of certain imaging services. CMS accepted the Relative Value Scale Update Committee (RUC) suggested values for 10 codes that pertain to radiology-related services.

First identified via the high-volume growth screen in 2008, 73580 (Radiologic examination, knee, arthrography, radiological supervision and interpretation) is receiving a new work relative value unit (RVU) for CY 2023. CMS finalized accepting the RUC-recommended work RVU of 0.59, in addition to direct practice expense (PE) inputs without refinement, as recommended by the RUC.