AAO-HNS Summary of CY 2023 MPFS Final Rule

Following the Centers for Medicare & Medicaid Services’ (CMS) release of the CY 2023 Final Rule for the Medicare Physician Fee Schedule (MPFS), which also includes proposals related to the Quality Payment Program (QPP), the AAO-HNS prepared a high-level summary of key proposals impacting the specialty.

Conversion Factor

The finalized CY 2023 Medicare conversion factor is $33.06, a decrease of 4.47% from the CY 2022 MPFS conversion factor of $34.61. Physicians were facing a cumulative cut of 8.47% on January 1, 2023, for Medicare reimbursement rates, comprised of a 4% PAYGO cut and a 4.47% cut in the conversion factor. The Consolidated Appropriations Act of the 2023 legislative package, delayed the 4% PAYGO cut for 2023, but only provides a partial 2.5% relief to the Medicare conversion factor for 2023, resulting in a 2% cut for physicians starting on January 1, 2023.

Additionally, this package provides a +1.25% adjustment to the not yet established Medicare conversion factor for 2024. This is half of what is being provided for 2023. The 4% PAYGO portion of the scheduled cuts for 2023 and 2024 will be delayed. Absent congressional action, physicians will face an 8% cut for Medicare reimbursement rates in 2025.

After months of intensive lobbying by the AAO-HNS and our specialty provider partners, coupled with grassroots outreach by Academy members to their congressional representatives and congressional leadership, the Academy is extremely disappointed that Congress did not act to fully eliminate the scheduled Medicare reimbursement cuts. Allowing even a portion of these cuts to go into effect will only further exacerbate the financial hardship physicians are currently facing and will threaten seniors’ access to medical care.

Estimated Impact to Otolaryngology

The overall impact of the CY 2023 MPFS finalized changes is estimated to be a 1% decrease for otolaryngology. This decrease is attributed to work RVU changes and is largely the result of the redistributive effects of the revaluation of evaluation and management (E/M) visits. When accounting for the expiration of the Protecting Medicare and American Farmers from Sequester Cuts Act, the true impact to the specialty is estimated to be a 4% reduction.

Evaluation and Management Visits

CMS adopted the revised CPT E/M guidelines and codes for inpatient and observation, emergency department, nursing facility, domiciliary or rest home, home, and cognitive impairment assessment E/M visits (referred to as “other E/M visits”). As part of this change, practitioner time or medical decision making can be used to select the E/M visit level. This is consistent with the approach adopted by CMS in 2021 for office/outpatient E/M visits.

CMS is adopting the AMA/Specialty Society RVS Update Committee (RUC) recommended relative values for these E/M visits; however, Medicare-specific coding will be created to enable payment of prolonged E/M visit services. These services will be reported with three separate Medicare-specific G codes.

Split (or Shared) E/M Visits

CMS finalized a one-year delay of its split (or shared) visit policy that would require a physician to see a patient for more than half of the total time in order to bill for the service. Due to this delay, clinicians who provide split (or shared) visits will continue to have a choice of history, physical exam, or medical decision making, or more than half of the total practitioner time spent to define the substantive portion, instead of using total time to determine the substantive portion.

Telehealth – Audiology Services

During the Public Health Emergency (PHE), practitioners developed the capacity to perform audiology services using remote technology, including specialized equipment inside an audiometric soundproof booth. In recognition, CMS finalized the addition of the following audiology services to Medicare Telehealth Services List on a Category 3 basis. This addition allows these services to be provided via telehealth through the end of CY 2023. In future rule making, CMS will consider permanently adding these services and other audiology services to the Medicare Telehealth Services List.

Audiology Services 

A subset of diagnostic audiologist services will be covered and paid when furnished without a referral from a physician or a non-physician practitioner (NPP) for a non-acute hearing assessment unrelated to disequilibrium, or hearing aids, or examinations for the purpose of prescribing, fitting, or changing hearing aids.

While CMS initially proposed to create HCPCS code GAUDX to describe these audiology services, many commenters, including the Academy, expressed their opposition to this proposed framework. Persuaded, CMS will instead require audiologists to use the individual CPT codes to identify the services furnished without a referral and append the new AB modifier.

The following are the CPT codes that audiologists can bill with the AB modifier for non-acute hearing conditions without a physician or a NPP order.

Valuation of Services

CMS finalized the following new CPT codes descriptions and/or valuations that impact the specialty.

Energy Based Repair of Nasal Valve Collapse

• 30468 – Repair of nasal valve collapse with subcutaneous/submucosal lateral wall implant(s)
  • Work RVU – 2.80
• 30469 – Repair of nasal valve collapse with low energy, temperature-controlled (i.e., radiofrequency) subcutaneous/submucosal remodeling
  • Work RVU – 2.44

Drug Induced Sleep Endoscopy (DISE)

• 42975 – Drug-induced sleep endoscopy, with dynamic evaluation of velum, pharynx, tongue base, and larynx for evaluation of sleep-disordered breathing, flexible, diagnostic
  • Work RVU – 1.58

Transcutaneous Passive Implant-Temporal Bone

• 69714 – Implantation, osseointegrated implant, skull; with percutaneous attachment to external speech processor
  • Work RVU – 6.68
• 69716 – Implantation, osseointegrated implant, skull; with magnetic transcutaneous attachment to external speech processor within the mastoid and/or resulting in removal of less than 100 mm2 surface area of bone deep to the outer cranial cortex
  • Work RVU – 9.03
• 69717 – Revision/replacement (including removal of existing device), osseointegrated implant, skull; with percutaneous attachment to external speech processor
  • Work RVU – 7.91
• 69719 – Revision/replacement (including removal of existing device), osseointegrated implant, skull; with magnetic transcutaneous attachment to external speech processor, within the mastoid and/or involving a bony defect less than 100 mm2 surface area of bone deep to the outer cranial cortex
  • Work RVU – 9.46
• 69726 – Removal, entire osseointegrated implant, skull; with percutaneous attachment to external speech processor
  • Work RVU – 6.36
• 69727 – Removal, entire osseointegrated implant, skull; with magnetic transcutaneous attachment to external speech processor, within the mastoid and/or involving a bony defect less than 100 mm2 surface area of bone deep to the outer cranial cortex
  • Work RVU – 7.38
• 69728 – Removal, entire osseointegrated implant, skull; with magnetic transcutaneous attachment to external speech processor, outside the mastoid and involving a bony defect greater than or equal to 100 mm2 surface area of bone deep to the outer cranial cortex
  • Work RVU – 8.50
• 69729 – Implantation, osseointegrated implant, skull; with magnetic transcutaneous attachment to external speech processor, outside of the mastoid and resulting in removal of greater than or equal to 100 mm2 surface area of bone deep to the outer cranial cortex
  • Work RVU – 9.97
• 69730 – Revision/replacement (including removal of existing device), osseointegrated implant, skull; with magnetic transcutaneous attachment to external speech processor, outside the mastoid and involving a bony defect greater than or equal to 100 mm2 surface area of bone deep to the outer cranial cortex
  • Work RVU – 10.25

Rebasing and Revising the Medicare Economic Index (MEI)

CMS has finalized new MEI weights for the different cost components, primarily using data from the Census Bureau’s Service Annual Survey (SAS). The current MEI weights are based primarily on results from the AMA’s Physician Practice Information (PPI) survey, which utilized 2006 data. This is a significant adjustment that would lead to substantial changes in the weights for many of the key components of physician practice expense (the weight for non-physician compensation increases from 16.6 percent to 24.7 percent in the new MEI). As a result, CMS will not implement the MEI changes in 2023 and will seek continued public comment due to the significant impact to physician payments.