The Problem

The 2023 Medicare Physician Fee Schedule (PFS) Final Rule issued on November 2, 2022, would impose yet another round of significant cuts to office-based specialists. These cuts will continue to accelerate the health system consolidation trend, exacerbate health inequities in a variety of diseases, and threaten the pandemic resilience of our healthcare system. 

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“Budget-neutrality” remains a driver of cuts within the fee schedule as the 2023 as it incorporates: 
 

• A carry-over 3% cut to the conversion factor from the 2021 PFS E/M policy;

• The second-year of clinical labor cuts from the 2022 PFS Clinical Labor policy that cuts some specialists by another 4 – 5%; and

•  Another 1.5% cut to the conversion factor from still further E/M policies in the 2023 PFS.

 

As a result, certain office-based specialists will again be cut by another 9% in 2023 alone. 

 
These year-over-year cuts are being implemented without regard to patient outcomes, actual PFS provider resource needs, or any other rationale policy. 
 
In the 2023 PFS Final Rule, CMS states, “In light of feedback from interested parties, CMS has prioritized stability and predictability over ongoing updates.”  We urge CMS and Congress to follow through on this statement and stop ongoing clinical labor and EM cuts to office-based specialists in end-of-year Medicare legislation as Congress looks to undertake the serious work of fundamental reform to the Physician Fee Schedule.