AHCA/NCAL Submit Comments on Medicare Physician Fee Schedule Proposed Rule

CMS; Medicare; AHCA/NCAL Updates

AHCA/NCAL submitted two comment letters on behalf of its membership, in response to an extensive proposed rule issued by the Centers for Medicare and Medicare Services (CMS). The letters are regarding the CY 2023 Physician Fee Schedule proposed rule, which discusses the proposed revisions to Medicare Part B benefit coverage and payment rates paid to physicians and other healthcare providers, as well as other policies including provider enrollment.    
The first comment letter is from AHCA specifically as it involves several proposed policies to revise provider enrollment regulations impacting all providers. It also has a significant proposed change that would redesignate SNFs from a limited-risk provider to a high-risk provider designation. This designation change would mean federal background fingerprint checks on all new SNF provider enrollment or with any change of ownership, including change in limited investors.  Any revalidating providers and new SNFs would also be subject to additional onsite surveys from the Medicare Administrative Contractor if adopted.   
The second comment letter is from AHCA and NCAL as it involves traditional fee schedule rule policies impacting Medicare beneficiaries in both settings. The comment letter addresses the following topics: 

  • ​CY 2023 PFS Ratesetting and Conversion Factor  
  • Payment for Medicare Telehealth Services Under Section 1834(m) of the Act  
  • Proposals and Request for Information on Medicare Parts A and B Payment for Dental Services  
  • Proposal to Rebase and Revise the Medicare Economic Index (MEI) in CY 2024  
  • Modifications Related to Medicare Coverage for Opioid Use Disorder (OUD) Treatment Services Furnished by Opioid Treatment Programs (OTPs)  
  • Proposals to Revise the Medicare Shared Savings Program  
  • Proposal to Revise the Requirement for Electronic Prescribing for Controlled Substances for a Covered Part D Drug under a Prescription Drug Plan or an MA–PD Plan (section 2003 of the SUPPORT Act)  
  • Proposed Revisions to the ‘Incident to’ Physicians’ Services Regulation for Behavioral Health Services  
  • Chronic Pain Management and Treatment (CPM) Bundles (HCPCS GYYY1, and GYYY2)  

Contact dciolek@ahca.org with any questions.