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CMS Releases Final Rule for CY 2022 Medicare Physician Fee Schedule

The CY 2022 Medicare Physician Fee Schedule final rule promotes greater telehealth utilization and boosts payment rates for vaccine administration.

Jacqueline LaPointe
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Published: 03 Nov 2021

UPDATED CMS has finalized the calendar year (CY) 2022 Medicare Physician Fee Schedule to promote greater telehealth utilization, boost reimbursement rates for vaccine administration, and improve health equity, among other initiatives, the federal agency said.

The final rule will implement “a series of standard technical proposals” as part of CY 2022 rate-setting, CMS said. The conversion factor for next year will be $33.59, a decrease of $1.30 versus the CY 2021 conversion factor. Next year’s rate accounts for statutory changes to relative value units (RVUs) and the expiration of the 3.75 percent temporary CY 2021 payment increase Congress approved through pandemic-related legislation.

The CY 2022 conversion factor also reflects a statutory update of 0 percent and an adjustment necessary to account for changes in RVUs and expenses that would result from our finalized policies, according to the final rule.

Other finalized policies include the elimination of geographic barriers when it comes to using telehealth for behavioral healthcare. The final rule enables patients to access telehealth services in their homes versus a qualifying healthcare site for diagnosis, evaluation, and treatment of mental health disorders.

“The COVID-19 pandemic has highlighted the gaps in our current health care system and the need for new solutions to bring treatments to patients, wherever they are,” CMS Administrator Chiquita Brooks-LaSure said in an announcement. “This is especially true for people who need behavioral health services, and the improvements we are enacting will give people greater access to telehealth and other care delivery options.”

The Medicare Physician Fee Schedule will pay for mental health visits furnished by rural health clinics and federally qualified health centers using telehealth, including audio-only telephone calls, for the first time outside of the COVID-19 public health emergency (PHE), CMS noted.

The agency also finalized an extension for services added to Medicare’s telehealth list during the COVID-19 PHE until CY 2023. The rule also extended inclusion of some cardiac and intensive cardiac rehabilitation codes on the telehealth list through the end of CY 2023. 

Through the CY 2022 Medicare Physician Fee Schedule final rule, CMS will also support another high priority from the COVID-19 PHE: vaccine administration.

The agency finalized in the rule a higher Medicare reimbursement rate for the administration of certain vaccines. The rule states that Medicare will pay $30 per dose for the administration of the influenza, pneumococcal and hepatitis B virus vaccines and will continue to pay $40 per dose for administration of the COVID-19 vaccines.

Medicare reimbursement rates for in-home administration will be $35.50 through the end of the COVID-19 PHE and $450 for administration of COVID-19 monoclonal antibody treatments in healthcare settings. The rate for in-home administration will be $750.

Also finalized in the new rule are new policies regarding split, or shared, evaluation and management (E/M) visits, implementation of new modifiers for physical and occupational therapy services furnished by physical therapist assistants and occupational therapy assistants, and authorization of the direct payment of physician assistants for qualifying services.

To view the complete final rule, click here. Please note that the rule has been filed on the Federal Register but has not yet been published. Stay tuned for more coverage.

Providers decry cuts to physician reimbursement

Healthcare industry groups are coming out against the reduced conversion factor in CY 2022.

“While the American Medical Association (AMA) will thoroughly analyze the 2,400+ page rule, it is a reminder of the financial peril facing physician practices at the end of the year,” Gerald E. Harmon, MD, president of the AMA, said in a statement on Wednesday.

AMA reported that the reduction in the conversion factor is about 3.85 percent. But that cut is on top of other looming Medicare physician reimbursement reductions, which could reach close to 10 percent of physician payments next year if Congress does not interview.

Providers have said that they will have to reconsider physician compensation, freeze hiring new clinicians and staff members, and even delay population health initiatives if they lose 8 to 10 percent of Medicare reimbursement next year.

“Failing to prevent these cuts could result in significant challenges,” said Jerry Penso, MD, MBA, president and CEO of AMGA (American Medical Group Association), which also conducted the survey asking providers what they would do if full physician reimbursement cuts were enacted.

“Our members will need to make hard choices, and will need to consider hiring freezes and layoffs, as well as service line eliminations. It’s a critical situation, and Congress needs to treat it as such,” Penso added.

But MSSP changes to help ACOs

While industry groups decry physician reimbursement cuts in the CY 2022 Medicare Physician Fee Schedule, changes to the Medicare Shared Savings Program—the largest accountable care organization (ACO) model to date—are being welcomed.

The National Association of ACOs (NAACOS), for example, commended CMS for delaying the introduction of electronic clinical quality measures (eCQMs) for ACO quality reporting under the program for three years, one year longer than originally planned.

“For more than a year, NAACOS has cited numerous potential negative consequences to patient care among the many reasons why such a rapid shift to electronic clinical quality measure (eCQM) reporting was bad policy. We appreciate CMS listening to ACOs, providers, and the health IT vendor community on the need for more time and additional changes,” Clif Gauc, ScD, president and CEO of NAACOS, said in a statement on Tuesday.

NAACOS was “also pleased to see the agency minimize administrative and financial burdens for repayment mechanism requirements by cutting in half the amount ACOs must secure as a financial guarantee when they move to risk-based models.”

“We hope to see more of this type of burden reduction from the agency across other aspects of the MSSP. However, NAACOS is disappointed CMS didn’t use this regulation as an opportunity to make needed adjustments to ACO benchmarking and risk adjustment policies,” Gaus explained.

NAACOS is hoping CMS will make changes in future rulemaking to eliminate ACO-assigned beneficiaries from an ACO’s regional reference populations and cap risk scores in an ACO’s region at the same level of the ACO. The changes would “create more fair and accurate spending targets for ACOs,” Gaus said.

This article was originally published on 11/02/2021.

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