OCAN Comments on the Medicare Physician Fee Schedule Proposed Rule for Calendar Year 2023
On behalf of the Obesity Care Advocacy Network (OCAN), we appreciate the opportunity to provide comments in response to the Centers for Medicare & Medicaid Services (CMS) Medicare Physician Fee Schedule (MPFS) proposed rule for calendar year (CY) 2023. We welcome the opportunity to work with CMS to address the needs of Medicare beneficiaries living with obesity and ask that you consider our comments on the proposed rule.
OCAN appreciates CMS’s interest and recognition of the important role that caregivers play in supporting the health and well-being of Medicare beneficiaries. We also support of the AMA/Specialty Society RVS Update Committee’s (RUC) work in developing the Caregiver Behavior Management Training CPT codes 96X70 and 96X71 as the rationale behind these codes is to support the necessary services that many beneficiaries require to improve clinical outcomes related to the primary diagnosis and care plan. We urge CMS to consider implementing payment for these important services under the PFS for CY 2023 and accept the initial RUC recommendations of a work RVU of 0.43 for CPT code 96X70 and a work RVU of 0.12 for CPT code 96X71.
OCAN commends CMS’s actions aimed at looking for ways to increase utilization for the many high-value but vastly under-utilized Medicare benefits that not only promote beneficiary health and wellbeing but are also cost-effective. OCAN offers comments on Intensive Behavioral Therapy for Obesity (IBT for Obesity), which is not being utilized to its full potential. Under current rules, IBT for Obesity can only be covered if Medicare beneficiaries receive the service from—or under the supervision of—their physician or other primary care provider (PCP) in a primary care setting (such as a physician’s office). OCAN believes that CMS should allow other providers, including registered dietitians, psychologists, other physician specialties and community-based lifestyle programs, to serve as direct providers for the IBT for Obesity benefit and allow them the ability to see these patients outside of the primary care setting upon referral from a physician.