AUA Submits Comments on the Calendar Year 2023 Medicare Physician Fee Schedule Proposed Rule

By Policy and Advocacy Brief posted 09-08-2022 14:03


On September 1 the AUA submitted comments in response to the Calendar Year (CY) 2023 Medicare Physician Fee Schedule. Our comments to the Centers for Medicare & Medicaid Services (CMS) focus on the following:

  • Conversion Factor Update
  • CMS’s Proposed Valuation of Urology-Specific Codes for CY 2023 (Percutaneous Nephrolithotomy)
  • Evaluation and Management (E/M) Services
  • Payment for Medicare Telehealth Services
  • Requiring Manufacturers of Certain Single-dose Container or Single-use Package Drugs to Provide Refunds with Respect to Discarded Amounts
  • Strategies for Improving Global Surgical Package Valuation
  • Rebasing and Revising the Medicare Economic Index (MEI)
  • Strategies for Updates to Practice Expense Data Collection and Methodology
  • Medicare Potentially Underutilized Services
  • Merit-Based Incentive Payment System (MIPS) Value Pathways (MVPs)
  • Request for Information: Health Equity Measures

The AUA placed particular emphasis on CMS’ proposed valuation of urology-specific codes for Percutaneous Nephrolithotomy (PCNL) CPT codes (50080 and 50081), urging CMS to finalize the RUC-proposed values as it maintains the relativity of the procedures and accounts for the time, mental effort and skill associated with the codes. The AUA also signed onto comment letters regarding the proposed implementation of the clinical labor rate submitted to CMS by the Clinical Labor Coalition and the Alliance for Specialty Medicine.

The AUA previously met with CMS, as detailed in the August 30 AUA Public Policy Update, to discuss these issues and expects CMS to issue the CY 2023 Medicare Physician Fee Schedule final rule in early November 2022. The AUA’s finalized comment letter is attached for your review.