The Effects of the 2023 MPFS Proposed Rule on Neurology Billing

The Effects of the 2023 MPFS Proposed Rule on Neurology Billing

CMS has recently unveiled the CY 2023 revisions to the payment policies within the MPFS. Also, it is coupled with other changes to Medicare Part B payment policies. This blog delves into the implications that the 2023 MPFS proposed rule holds for neurology billing, spotlighting key takeaways.

The 2023 MPFS Proposed Rule and Neurology Billing

• CMS has projected that the rule’s provisions will have a neutral impact on neurosurgery. Nevertheless, the proposed CY 2023 conversion factor (CF) by CMS is set at 33.0775. So, it has marked a reduction of 4.42 percent (rounded to 4.5%) in comparison to the 2022 CF of 34.6062. This reduction is in addition to the deferred 4% pay-as-you-go reduction. Congress put it on hold last year. Also, we may observe the reinstatement of the 2% annual Medicare payment sequester.
• CMS received a request to potentially reevaluate CPT code 23091. It is a neurology billing code for allograft structural spine surgery only. The requester asked so due to potential misvaluation of the code. Anyhow, the agency disagrees with the rationale provided by the requester. Consequently, CMS proposes not to classify this procedure as misvalued for neurology billing services.
• CMS is actively considering proposals to recalibrate and update the Medicare Economic Index (MEI) cost share weights. The agency is actively seeking input on this matter for neurology billing and coding. MEI serves as a gauge for input prices concerning physician services. The proposed new methodology aims to reflect current market conditions more effectively. So, this will be useful for both ‘physician ownership practices’ and self-employed physicians. This update would allow for more frequent updates to the MEI. Meanwhile, this change wouldn’t impact the overall spending on MPFS. But it could significantly influence payments for specific specialties. CMS doesn’t intend to employ the updated MEI data for setting payment rates in CY 2023. Instead, the agency is soliciting feedback on its future application.
• The proposed rule is being analyzed by the American Association of Neurological Surgeons (AANS) and Congress of Neurological Surgeons (CNS). This analysis projects an approximate 8 percent reduction in total allowed charges for neurology billing. It is possible if CMS adopts the proposed rebased and revised MEI cost share weights for RVU adjustment.
• In a notable move, CMS proposes the exclusion of 125 minutes of equipment time for an exam light in spine CPT codes 63020 and 63030. This decision comes in response to the RUC’s contestation of its typical usage for assessing wounds and removing staples. It’s essential to note that such equipment is standard in neurosurgical and orthopedic exam rooms.
• CY 2022 marked the final year of a multi-year phased update for practice expenses (PE) concerning supplies and equipment. Simultaneously, it marked the initial year of a four-year phase-in to update PE clinical labor pricing. For this reason, CMS has considered that the previous data for this component was nearly two decades old. FY 2023 serves as the second year of this phased-in update, and CMS is welcoming comments about potential concerns regarding its implementation process.
• CMS is actively seeking public input on strategies to enhance the accuracy of global surgery code values. The agency maintains its stance that RVUs for these services are currently inaccurate.
• As part of a continuous effort to update E&M visits and related medical billing and coding guidelines, CMS is poised to adopt a significant portion of the AMA CPT Editorial Panel-approved revised coding and updated guidelines for various E&M visits. This expansion includes inpatient, observation, emergency department, nursing facility, and home/residence service visits.
• Moreover, CMS has decided to postpone its proposal for ‘split or shared’ E&M visits, which pertain to visits conducted in a facility by both a physician and a non-physician provider within the same group. Initially slated for implementation in 2024, this rule’s adjustment stipulates that the practitioner who contributes a substantial portion of the visit’s time would be the one eligible to bill for the visit. CMS now seeks to delay this change, allowing clinicians who furnish split (or shared) visits to continue using history, physical exam, medical decision-making, or time spent to define the substantive portion, instead of relying solely on total time for this determination.
• In alignment with its ongoing initiative started in 2021 to retire outdated National Coverage Determinations (NCDs), CMS is proposing to discontinue the NCD for Ambulatory Electroencephalographic Monitoring. Public feedback on this matter is welcomed by the agency from neurology billing and service providers.
• While CMS does not intend to include CPT codes 95976 and 95977 (analysis of cranial nerve neurostimulation) on the Medicare telehealth services list due to limitations in two-way audio-video communication technology, the agency remains open to considering additional evidence regarding the feasibility of providing these services through telehealth in the future.
• Conversely, CMS is proposing the addition of CPT codes 95970, 95983, and 95984 (general brain nerve neurostimulation) to the Medicare telehealth services list under Category 3, with the request for comments on concerns related to patient safety and whether these services are suitable for inclusion beyond the scope of public health emergencies (PHE).

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