The American Venous Forum is committed to promoting evidence-based best practices to ensure that patients have access to the highest quality care – especially the underserved.

We believe that vigorous advocacy in venous and lymphatic disease is critical to this commitment.

The AVF is actively advocating on behalf of our members and the patients they serve.  The following are just a few of the comment letters we have submitted as the AVF or as part of a larger coalition:

• AVF Letter to CMS
• Coalition – CY 2022 Payment Policies under the Physician Fee Schedule
• Coalition – CY 2022 Payment Policies under the Physician Payment Schedule and Other Changes to Part B Payment Policies
• AVF and SVS Comment to CMS – Transvenous Pulmonary Embolectomy NCD

Today, the Centers for Medicare & Medicaid Services (CMS) released the 2023 Medicare Physician Payment Schedule final rule. Notably, CMS adopted the revised CPT guidelines and codes and the AMA/Specialty Society RVS Update Committee (RUC) recommended relative values for additional E/M visit code families, including hospital visits, emergency department visits, home visits and nursing facility visits. These changes allow time or medical decision-making to be used to select the E/M visit level. In total, the E/M code sets being revised for 2023 comprise approximately 20 percent of all allowed charges under the Medicare Physician Payment Schedule. Therefore, these changes are estimated to require a reduction of about 1.6 percent to the 2023 Medicare conversion factor due to statutory budget neutrality requirements.

The CY 2023 Medicare conversion factor (CF) is $33.06, a decrease of $1.55 or 4.5% from the 2022 CF of $34.61. The decrease is largely a result of an expiring 3 percent increase funded by Congress through 2022. The additional approximate 1.6 percent decrease is the result of budget neutrality requirements that stem from the revised E/M changes. The AMA and the Federation are strongly advocating that Congress avert this payment cut, as well as implement an inflationary update for physicians, extend the 5 percent Advanced APM incentive and prevent the steep increase to the participation requirements for APMs, and waive the 4 percent PAYGO sequester. 

In response to the Consolidated Appropriations Act, which extended payment for telehealth services to all communities in the country, not just rural areas, and allowed patients to receive telehealth services in their home for 151 days, or five months, after the end of the COVID-19 public health emergency (PHE) ends, CMS finalized its proposal to extend telehealth coverage for the codes that were only going to be on the telehealth list through the end of the PHE for an additional five months.

AMA staff are closely reviewing the final rule and will draft a detailed summary and analysis to share shortly. Please see the following documents for more information:

• Final Rule – https://www.cms.gov/files/document/cy2023-physician-fee-schedule-final-rule-cms-1770f.pdf
• CMS Press Release – https://www.cms.gov/newsroom/press-releases/hhs-finalizes-physician-payment-rule-strengthening-access-behavioral-health-services-and-whole
• CMS Fact Sheet – https://www.cms.gov/newsroom/fact-sheets/calendar-year-cy-2023-medicare-physician-fee-schedule-final-rule
• CMS QPP Fact Sheet – https://qpp-cm-prod-content.s3.amazonaws.com/uploads/2136/2023%20Quality%20Payment%20Program%20Final%20Rule%20Resources.zip
• CMS MSSP Fact Sheet – https://www.cms.gov/newsroom/fact-sheets/calendar-year-cy-2023-medicare-physician-fee-schedule-final-rule-medicare-shared-savings-program

Venous leg ulcers are the most common indication for treatment in a wound center. Therefore, many venous specialists play pivotal roles in wound centers. In most cases, venous providers in wound centers provide the full gamut of advanced wound care therapies in addition to providing vein specific therapies.

The use of “Skin Substitutes” in the management of refractory Venous leg ulcers has been shown to be effective and is a covered service by most payers. However, the 2023: Hospital Outpatient Prospective Payment System (CMS-1772-P) proposed rule, lays out a variety of problematic changes; including changing the name of the product category, the size and anatomic location of wounds that can be treated, and the site of service where effective reimbursement can be obtained.

Seeing this as an extremely troublesome set of changes which would adversely impact our members’ ability to use “Skin Substitutes” (Cellularized Tissue Product (CTP)) for the benefit of our patients, the AVF Health Policy Committee worked via our membership in the Alliance for Wound Care Stake Holders to respond to Medicare (CMS). The proposed rule and our comment letter can be reviewed below. The AVF HPC will continue to advocate for you and your patients in all aspects of your practice.

PROPOSED RULE LINK

COMMENT LETTER LINK

Dr. Sheila Coogan, Chair – AVF Health Policy Committee
Dr. Mark Iafrati, Past Chair – AVF Health Policy Committee