Virtual care reimbursement and opportunities in the 2023 Medicare proposed rule—what you need to know now (July roundup)
Most people start thinking of vacations and barbecues with family and friends when July rolls around. But we are not most people, are we?
Those of us in healthcare innovation are focused on the breaking news of the Medicare Physician Fee Schedule (MPFS) Proposed Rule for the coming year.
Why? Because the MPFS:
Determines care options and reimbursement rates for providers for an entire year;
Expands or restricts avenues of innovation (and opportunities for revenue) for digital health companies; and
Influences private insurer reimbursement.
These are three excellent reasons why we put so much energy into analyzing the Proposed Rule for our clients and advocating on their behalf.
As usual, our team analyzed the MPFS Proposed Rule within 24 hours of release (that's 2000+ pages you don't have to read).
We dove deep into specific segments of the Proposed Rule to forecast the impact on care, revenue, and business models.
Then we distilled it into a series of blog posts—and an upcoming webinar you don’t want to miss!— so you can imagine what 2023 could look like for you if this Proposed Rule becomes the Final Rule at the end of this year.
(Don't like the way the future looks? We have an option for you at the end of this email.)
Now let's jump ahead to 2023 and see what you can expect (as of now, at least):
[webinar signup] Everything You Need to Know About the 2023 Proposed Medicare Physician Fee Schedule, July 21 at 1p Eastern. Don’t miss it!
[blog post] The Top 6 Takeaways from the MPFS Proposed Rule (posted 24 hours after release, as usual 💅)
[blog post] Changes to Remote Therapeutic Monitoring Reimbursement in the Proposed 2023 Medicare Physician Fee Schedule
What you can do now.
The best thing about the Proposed Rule (if you don’t like what it contains) is that it is not yet the Final Rule. CMS opens up a comment period through September 6, 2022, for stakeholders like you to provide feedback.
The hot take? CMS has to read every comment before it finalizes the MPFS.
Now is your time to share "on the ground" perspectives policymakers don't always fully grasp.
You can influence reimbursement and treatment options with your valuable insights and experience.
You have two options. First, you can click here to view the CMS comments submission process and make your voice heard.
Too busy, too overwhelmed, or lacking resources at the moment to take this on?
Then you want option two—we do it for you.
You'll get our legal and regulatory insights and advocacy experience to draft comments for you, all the way through to submission and receipt tracking.
If this sounds like something you want, then click here for the details on this done-for-you service. (Please don't delay, as this is not a cookie-cutter process. We will stop taking new requests by August 16 or when we meet capacity, whichever comes first.)
We do a few dozen of these every year, and clients see the impact of this effort in their ability to innovate, grow revenue, and serve patients. On behalf of our clients and alongside key stakeholder organizations, we advocated for changes to the RTM code set last year. CMS responded by creating four new HCPCS G codes this year to increase patient access to RTM and reduce the supervisory burden on physicians/NPPs. We’ll consider this a win for now, though we look forward to responding to CMS’s request for comments on RTM devices this year. The work continues!
Whether you submit comments yourself or ask us to do it for you, we hope you'll make your voice heard if you don't think the Proposed Rule reflects how you want to serve your clients in 2023.
The Don’t Miss List:
[webinar] Yep, we’re mentioning this again because you’re near the end of this email and you don’t want to miss learning Everything You Need to Know about the 2023 MPFS on July 21.
[video] Roe v. Wade for Healthcare Businesses, a 5-part series with femtech expert and host of Legally Femtech Podcast, Bethany Corbin, Esq. (We got so many rave reviews on this series, so if you missed it, please check it out!)
[podcast] "Hospital at Home" Initiatives for Hospitals and Digital Health Vendors with Health System Virtual Care Expert Casey Papp, Esq. on our Decoding Healthcare Innovation Podcast
[podcast] How to reduce burdens on providers through technology with Wellbe founder James Dias on our Decoding Healthcare Innovation Podcast
[news] The Public Health Emergency (PHE) declaration, which allows for many of the expanded telehealth options in use today, was extended for another 90 days on July 15. While this can go away at any 90-day interval, the federal government has pledged a 60-day notice before termination of the PHE.
And that brings this issue to a close…
Thank you for making room for us in your crowded inbox every month. You're busy, and we aim to deliver the most immediately useful information in each issue. You can always reply to any of our emails with kudos, comments, questions, or constructive criticism—we read every response.
Next month you'll learn about revenue models, one of our favorite topics. Until then, we wish you a fun summer with family and friends.
Until next time,
Carrie Nixon, Rebecca Gwilt,
and the entire team at Nixon Gwilt Law