NAACOS Analysis of the Final 2023 Medicare Physician Fee Schedule
Executive Summary
On November 1, the Centers for Medicare & Medicaid Services (CMS) released the Calendar Year (CY) 2023 Medicare Physician Fee Schedule (MPFS) Final Rule. This regulation includes several positive changes to the Medicare Shared Savings Program (MSSP) for which NAACOS has long advocated.
In this analysis, we provide details on key finalized policies impacting ACOs. The rule is summarized in several fact sheets provided by CMS: MPFS Fact Sheet, MSSP Fact Sheet and Quality Payment Program (QPP) Fact Sheet.
NAACOS provided detailed comments in response to the proposed 2023 MPFS rule, with key input from members. Most policies were finalized as proposed.
Medicare Shared Savings Program Policies
- Change the “Pathways to Success” glidepath to allow more time before advancing to risk for certain ACOs*
- Change the “Pathways to Success” glidepath to allow more time before advancing to risk for certain ACOs*
- Incorporate a prospectively projected administrative growth factor into a new three-way blend with national and regional growth rates to update an ACO’s historical benchmark for each performance year
- Account for an ACO’s prior savings in rebased benchmarks to help mitigate the lowering of an ACO’s benchmark over time
- Reduce the cap on negative regional adjustments from -5 percent to -1.5 percent
- Allow low revenue ACOs in the Basic Track more opportunities to earn shared savings
- Change the quality scoring approach to allow more ACOs to achieve a portion of savings*
- Add a health equity adjustment increase to quality scores for ACOs serving high proportions of underserved beneficiaries
- Provide advance investment payments to certain ACOs*
*Denotes policies for which NAACOS has long advocated
Medicare Physician Payment Policies
- Decrease the Medicare conversion factor from $34.61 to $33.06
- Update other evaluation and management (E/M) visits to reflect time spent or medical decision making
- Implement telehealth provisions established in the Consolidated Appropriations Act (CAA) of 2022