2022 Medicare PFS Proposed Rule Top 10 Takeaways

On July 13, 2021, the Centers for Medicare & Medicaid Services (CMS) published the 2022 Medicare Physician Fee Schedule Proposed Rule. The 1,747-page document covers topics such as telehealth services and changes to other healthcare services. The CodeToolz leadership team has compiled a Top 10 list highlighting what’s covered in the new proposed rule.

(1) Conversion Factor Reduction (and resulting payment cuts)

  • 2022 proposed physician conversion factor (CF) of $33.5848, representing a 3.75% reduction from the 2021 CF of $34.8931.

(2) Expanded List of Telehealth Services

  • Extension of coverage to the end of CY 2023 for services temporarily added to the Medicare Telehealth Services List during the pandemic.

(3) New Coverage for Tele-Behavioral Health Services

  • Beneficiaries will be able to receive a specific set of services through telehealth including evaluation and management visits (common office visits), mental health counseling and preventive health screenings.

(4) Evaluation & Management Visits Changes

  • A number of refinements to current policies for split (or shared) E/M visits.

(5) Payment for Physician Assistant Services

  • Physician assistants would be able to bill Medicare directly for their services and reassign payment for their services. Currently, Medicare can only make a payment to the employer or independent contractor of a PA.

(6) Continued Implementation of Appropriate Use Criteria

  • CMS is proposing to delay the implementation of a penalty phase of the Appropriate Use Criteria program. Currently the penalty phase is set to begin Jan. 1, but CMS proposed delaying it to Jan. 1, 2023, or the Jan. 1 that follows the end of the public health emergency.

(7) Changes to the Medicare Diabetes Prevention Program

  • Proposed changes to the Medicare Diabetes Prevention Program (MDPP) expanded model intended to boost supplier enrollment, with a goal of increasing beneficiary participation.

(8) New Coverage for Remote Therapeutic Monitoring (RTM) Services

  • The new codes are intended to expand the scope and reach of digital health technologies to reimburse monitoring of non-physiologic data.

(9) Increased Reimbursement for Care Management Services

  • The CCM/CCCM/PCM code family now includes five sets of codes, each with a base code and an add-on code. The sets vary by the degree of complexity of care, who furnishes that care (clinical staff or physician/NPP), and the time allocated for the services.

(10) Launch of Merit-Based Incentive Payment System Value Pathways

  • CMS proposed to increase the Merit-based Incentive Payment System performance threshold score providers must exceed to receive bonuses under the Quality Payment Program. CMS also unveiled the first seven optional MIPS value pathways that would begin in 2023. The seven payment pathways would be emergency medicine, chronic disease management, heart disease, anesthesia, lower-extremity joint repairs, rheumatology and stroke care.

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