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ATS Submits Comments to CMS on Medicare Physician Fee Schedule Rule
This week, the ATS joined CHEST in submitting comments on the proposed 2023 Medicare Physician Fee Schedule. The proposed rule covers a wide range of payment and regulatory compliance issues for physicians and other Medicare B providers. The joint ATS/CHEST comments covered a number of issues including:


Medicare Conversion Factor – the letter opposed proposed payment cuts in the 2023 conversion factor.

Split/Shared Billing– ATS/CHEST urged CMS to allow medical decision making, as opposed to majority of time, as the determining factor for who should submit for reimbursement in split/shared services.

Under-utilized Services – ATS and CHEST urge CMS to take steps to ensure highly effective, but under-utilized services like lung cancer screening, preventive vaccines, pulmonary rehabilitation and liquid oxygen are available to Medicare beneficiaries.


CMS is expected to issue a final payment rule in late November.

Last Reviewed: September 2022