NASS Insider

September 20, 2022

NASS Submits Comments to CMS on Medicare Physician Payments 2023 Proposed Rule

NASS recently submitted extensive comments to the Centers for Medicare and Medicaid Services (CMS) on their proposed rule for the Medicare physician fee schedule (PFS). NASS also signed on to a comment letter from the Alliance of Specialty Medicine.

CMS proposes a steep, 4.5% reduction in Medicare payments to physicians for 2023 due to statutory requirements and regulatory changes discussed in the rule. In contrast, most other Medicare providers, including Medicare Advantage (MA) plans, anticipate sizeable increases in their 2023 payments (eg, inpatient hospitals (4.3%); inpatient rehabilitation facilities (3.9%); hospices (3.8%); hospital outpatient departments (2.7%); and MA plans (8.5%).

NASS’ comments expressed deep concern about the proposed 4.5% reduction in the conversion factor. NASS recognizes the limited authority CMS has to modify statutorily mandated budget neutrality adjustments when calculating updates to the conversion factors. However, NASS is alarmed at the potential cascading impacts on both physician practices and clinical patient outcomes. We urged CMS to exercise its ability to take actions under its administrative authority and work with Congress to help mitigate the impact of these impending payment reductions.

In response to the proposed rule, NASS also provided comments on the following proposals:
  • Valuations for Specific Codes
    • Arthrodesis Decompression (CPT 22630, 22632, 22633, 22634, 63052, and 63053)
    • Lumbar Laminotomy with Decompression (CPT codes 63020, 63030, and 63035)
    • Consultation Codes (CPT codes 99241-99255)
  • Telehealth Proposals
  • Global Surgical Package
  • Indirect Practice Expense
  • Revising and Rebasing the Medicare Economic Index (MEI)
  • Potentially Misvalued Codes
  • Fracture Liaison Service
  • Quality payment Program (QPP) Proposal
For all of NASS’ comments on the proposals please visit: