In This Public Health Emergency Update:

  • Congress Discusses Medicare Reimbursement Cuts
  • 2023 Changes to CPT/HCPCS Codes
  • Behavioral Health Telemedicine
  • End of Year Credentialing Slowdowns
  • Post-pandemic Authorizations
  • General Updates

Congress Discusses Medicare Reimbursement Cuts

On November 1, the 2023 Medicare Physician Fee Schedule Final Rule was issued. With new payment rules and pending cuts in reimbursement, there is growing concern for the scope of the financial impact, amid marked inflation. Providers are calling for Congress to address the nearly 4.5% in cuts imposed by the final rule. The Supporting Medicare Providers Act of 2022 was introduced as a bill in September and currently has bipartisan support.

Separately, Congress is being asked to address the Statutory PAYGO sequestration anticipated to cut approximately 4% from 2023 Medicare payments. Previously, Congress has prevented or postponed Statutory PAYGO in years when legislation to increase the deficit was enacted.

EMB will be monitoring the actions of Congress regarding these important items. Current reports are optimistic that cuts might be less significant than existing projections, as Congress has historically intervened in similar cases. We will let our providers know once outcomes are finalized.

2023 Changes to CPT/HCPCS Codes

In 2023, several evaluation and management (E/M) CPT/HCPCS codes are being removed from use, and this will affect how you report your encounters to EMB. There will be changes to coding for hospital observations, consultations, nursing facilities, resident services, and prolonged services. These changes should ultimately make everything simpler. Diana will soon be sending out a guide on some of the larger changes for your reference.

Behavioral Health Telemedicine

CMS has acknowledged plans for behavioral telehealth after the PHE ends. For patients who have only received telehealth for behavioral health services prior to or during the PHE, an in-person face-to-face non-telehealth visit will need to take place within six months of the official end date of the PHE, if care continues to be received. This six-month time period refers to a patient’s first in-person visit only.

Beyond that, a patient who has had their initial in-person visit must continue to be seen in-person once every twelve months, in most cases. CMS may be willing to make exceptions to the subsequent in-person meetings, if special circumstances exist and proper documentation is provided.

End of Year Credentialing Slowdowns

For those providers who utilize EMB’s complimentary credentialing services, you may have noticed a slowdown in processes over the last six months. Please understand that this is a system-wide issue. Anyone involved in credentialing and contracting is currently experiencing these delays that are, unfortunately, expected to intensify as the end of the year approaches. We would like to acknowledge that EMB has consistently operated and will continue to operate in our credentialing processes as efficiently and accurately as is possible. If you have any questions about your specific pending credentialing, please reach out to Diana or EMB’s credentialing team.

Post-pandemic Authorizations

During the pandemic, many of the insurance plans with requirements for primary care physician (PCP) authorizations waived those provisions, and members were permitted to have encounters outside of their assigned PCP. Those waivers have largely been removed. Pre-pandemic rules apply once again. All office staff must return to those standards of operation by checking eligibility, authorization requirements, and whether or not a PCP change form is necessary.

General Updates

  1. In mid-October, the PHE was again extended for an additional 90 days. All HHS/CMS waivers will continue to be in place for the duration of the PHE and for 151 days beyond that.
  2. Providers should be aware of potential payment slowdowns from Medicare, as the holiday season approaches. Expect operations to pick back up in the new year.
  3. We would like to give you advance notice of EMB’s holiday hours this season. The office will be closed for Thanksgiving on November 24 and 25. In December, between Christmas and New Year’s Day, we are utilizing a system of floating holidays. This method will allow for members of EMB’s staff to be available to our providers nearly every weekday from December 22 through January 3. Your biller will be reaching out to you with her specific days off.
  4. As we anticipate the end of the pandemic, these semi-regular public health emergency updates are going to shift. The hope is to make this bulletin a more formal forum for offering answers to the questions brought to us by our providers about the health care sphere. Do not hesitate to reach out to EMB with your questions, as they arise.