capitol hill report: AAN COMMENTS ON PROPOSED 2023 MEDICARE PHYSICIAN FEE SCHEDULE
September 12, 2022
Latest Advocacy News
- The AAN recently signed onto five advocacy letters focusing on a number of priority issues. Two of the letters originated from the American Brain Coalition, with one in support of $3 million in financial support of the Neurology Drug Program at the FDA and another urging passage of H.R. 8454: Medical Marijuana and Cannabidiol Research Expansion Act, which would facilitate research into therapeutic use of marijuana and CBD. The Epilepsy Foundation authored another letter in support of the passage of H.R. 8454 by the Senate. We also signed onto a letter in support of extending telehealth flexibilities and a letter urging for the completion of the FY23 appropriations cycle to provide funding for federal research agencies.
- The AAN has been engaged on multiple fronts in efforts to reduce the burden of prior authorization (PA) and other obstacles facing our members. The AAN recently submitted comments to the Centers for Medicare & Medicaid Services (CMS) in response to the 2023 Hospital Outpatient Prospect Payment System (OPPS) proposed rule. The AAN enumerates concerns regarding the proposed expansion of hospital outpatient PA requirements. The AAN also joined with a number of other specialty societies in a sign-on letter, also to CMS, warning of the effect of PA in Medicare Advantage plans.
- The Department of Health and Human Services Office of the Inspector General reported Wednesday that only a small fraction of Medicare claims for telehealth during the COVID-19 pandemic were at high risk of being fraudulent. The agency watchdog examined claims from 742,000 providers and found 0.2 percent posed a high risk to Medicare for fraud, waste, or abuse. This report will help bolster the AAN’s efforts to preserve telehealth flexibilities over the long term.
Issue in Focus
On August 25, the AAN submitted 50 pages of comments to the Centers for Medicare & Medicaid Services in response to the 2023 Medicare Physician Fee Schedule proposed rule. The AAN’s comments cover a wide range of topics impacting neurology and neurology patients and were developed with the input of dozens of AAN subject matter experts.
The AAN’s comments raised serious concerns related to a significant reduction in the Medicare conversion factor. The AAN is highly supportive of requests to Congress to waive budget neutrality requirements and to appropriate necessary funds into the fee schedule to preserve patient access to care and avert a deeply damaging cut at a time when providers are still dealing with the effects of the pandemic. Although the conversion factor cut is deeply troubling, the AAN’s comments also offered support for several thoughtful proposals that are likely to benefit neurologists and neurology patients in the areas of telehealth, E/M coding and billing policies, and split (or shared) visits. The AAN’s comments also provided CMS with recommendations on how to best implement a variety of MIPS Value Pathways that are relevant to neurology, what first steps should be taken regarding global surgical package valuation, and a multitude of other policies.
The comment period closed on September 6 and the AAN will continue to engage with CMS and other stakeholders outside of the official comment period as appropriate. The AAN will also release a summary of any key changes and projected impacts on neurology and neurology patients when the final rule is released in November.