ACR Submits Comments About the 2023 Medicare Physician Fee Schedule Final Rule

The American College of Radiology® (ACR®) submitted comments to the Centers for Medicare and Medicaid Services (CMS) in December about the calendar year 2023 Medicare Physician Fee Schedule (MPFS) final rule. While there was no formal comment period associated with the rule, these informal comments directly to CMS staff reflect the College’s disapproval of certain key payment provision issues, as well as aspects of the Quality Payment Program’s (QPP) Merit-based Incentive Payment System (MIPS).

Topics specifically addressed in the letter include: strategies for updates to practice expense data collection and methodology; issues related to neuromuscular ultrasound; and the effects on radiology practices caused by the increasing MIPS performance threshold, the limited number of applicable participation measures and the costs to participate.

Questions about the MPFS final rule should be directed to Katie Keysor, ACR Senior Director of Economic Policy.