On July 7, the Centers for Medicare & Medicaid Services (CMS) published the 2023 Physician Fee Schedule (PFS) proposed rule. Here’s a quick briefing of the six things most likely to have an impact on labs and the businesses that own them.
1. Changes to PAMA Reporting
In response to recent shuffling in Protecting Access to Medicare Act of 2014 (PAMA) price data reporting, the PFS proposes to change PAMA reporting timelines and requirements by clarifying that:
- The “data collection period” is January 1, 2019, through June 30, 2019, for the “data reporting period” of January 1, 2023, through March 31, 2023
- Data reporting officially began on January 1, 2017, and is required every three years, starting January 2023
2. Revised PAMA Reimbursement Cut Caps
In response to delays in scheduled PAMA price cuts, CMS wants to change the part of the PAMA regulations requiring the phase-in of payment cuts to indicate that the payment for CY 2022 may not be reduced by more than 0 percent, as compared to CY 2020, and that 15 percent will be the maximum payment cut for CYs 2023 through 2025.
3. Specimen Collection Fee Codification
CMS is proposing to “codify and clarify various laboratory specimen collection fee policies” included in the Medicare Claims Processing Manual that don’t have corresponding regulations and for which the manual guidance no longer applies.
4. New Travel Allowance Requirements
CMS wants to create new regulations governing travel allowances for specimen collection with regard to:
- General requirements
- Travel allowance basis
- Travel allowance amount
- Travel allowance calculation
5. Expanded Coverage of Colorectal Cancer Screening
CMS wants to make two changes to expand Medicare coverage of colorectal cancer screening to align with new U.S. Preventive Services Task Force (USPSTF) guidelines:
- Reducing the minimum age payment limitation for certain colorectal cancer screening to 45 years
- Covering follow-on screening after a Medicare covered non-invasive stool-based colorectal cancer screening test returns a positive result
6. The 3% Physician Pay Cut
To help doctors weather the revenue losses of the COVID-19 pandemic, CMS bumped up fee schedule payments by three percent in 2022. That bump is going away. But instead of keeping the fee schedule conversion factor it uses to calculate Medicare payments to physicians flat, CMS wants to reduce it from $34.61 to $33.08 per unit in 2023. Physicians also face the prospect of another cut of four percent under Pay-As-You-Go (PAYGO) rules calling for mandatory cuts when federal spending for a year reaches a specified threshold.