CMS is receiving pushback on its plan to create three new prolonged services codes.
Healthcare stakeholders, ranging from specialty societies to individual coding consultants, have urged CMS to abandon its plan to create three new prolonged services codes in comments submitted in response to the proposed 2023 Medicare physician fee schedule (MPFS).
Industry stakeholders described the three-code proposal for prolonged services as disappointing, burdensome, and confusing, according to Part B News.
For example, the American Association of Oral and Maxillofacial Surgeons said it was disappointed that CMS did not intend to accept the CPT® coding update to prolonged services and expressed concerns that two coding systems “will create administrative burden and undue confusion on the part of healthcare providers and coders.”
The American Academy of Neurology predicted CMS’ proposed policy will “lead to confusion among practitioners and prove to be disruptive when medical specialty societies educate members about the correct coding for prolonged service.”
Both specialty societies urged CMS and the workgroup to come to an agreement on how to define prolonged services for their revenue cycle.
According to Part B News, one commenter, a self-described professional billing consultant from Ohio, said the plan “makes no sense” and noted that it would not simplify coding. “If you are seeking ‘administrative simplicity,’ you should work it out with CPT and agree. The two of you having completely different numbers for the same [services] is going to be extremely confusing, ” the commenter said.
CMS’ original plan to use time to determine whether the treating physician or qualified health care professional (QHP) performed the substantive potion of a split/shared visit isn’t picking up any fans, based on a review of posted comments, Part B News said.
In the final 2022 MPFS rule, CMS said that it would allow practices to determine the substantive portion of the visit based on time or performance of key components for one year to allow providers to get used to the new policy. In the 2023 proposed rule, the agency announced plans to extend its policy another year.
However, the comments indicate that stakeholders want the option to bill based on time or key components—time or medical decision-making after 2022—to be permanent.
These aren’t the first groups to urge changes of the rule.
Both the Medical Group Management Association and the American Hospital Association submitted comprehensive comments to CMS in response to the rule as well.
The associations urged Congress to provide a positive update to the conversion factor, finalize the proposal to align telehealth services, and adjust subgroup reporting requirements under the MIPS value pathways, among other changes for 2023.
“Practices and coding educators will have to wait for CMS’ final decision. The final fee schedule is expected to be out in early November. However, the key lesson is that practices should be aware of what CMS is planning and wait until the final rule comes out to train staff,” Part B News said.
Amanda Norris is the Revenue Cycle Editor for HealthLeaders.