The proposed 2022 Medicare Physician Fee Schedule (PFS)

The proposed 2022 Medicare Physician Fee Schedule (PFS)

CMS has proposed a new rule Medicare physician fee schedule that would update the existing Medicare physician fee schedule and aiming for more health equity and telehealth utilization among physicians.

In the rule, CMS proposed a new Alternative Payment Model (APM) that is helpful for participants in MIPS APMs to provide consistency in data reporting. In addition, several changes to the Quality Payment Program (QPP) have been proposed that included delaying the implementation of the Merit-Based Incentive Payment System (MIPS) Value Pathway framework. By looking at these policies various healthcare leaders are having mixed reactions about the proposed rule as the rule contained some good and bad policies.

In this blog, you will get more clarity about various policy that proposed in a Medicare Physician Fee Schedule (PFS) proposed rule.

Reduction in the conversion factor

Reimbursement is important for every healthcare practice and the conversion factor plays important role in reimbursement. However, the proposed rule will establish a new conversion factor that is a reduction of over a dollar compared to the conversion factor this year. (The conversion factor in 2022 would be $33.58). However, rising inflation can harm certain specialists once a new conversion factor got established. Moreover, the proposed conversion factor reflects a statutory update of 0.00 percent and necessary adjustments based on changes in relative value units (RVUs) and expenditures from other proposed policies in the rule.

Changes to the shared savings program

The rule included significant changes to Medicare’s flagship accountable care organization (ACO) program, shared savings program which includes a longer transition to new electronic quality reporting requirements.

This step from CMS is applauded by various healthcare leaders as the healthcare industry, including ACOs, electronic health record (EHR) vendors, and government payers are looking for more time before mandating electronic quality measures and CMS has considered it.

Moreover, CMS is considering letting accountable care organizations (ACOs) in the Medicare Shared Savings Program (MSSP) opt to remain at their current level within the BASIC glide path (Opens in a new window) for an additional performance year in its proposed rule.

However, AMGA opposes the requirement that ACOs deferring advancement skip a level in the glide path. Based on the Covid-19 pandemic, an ACO that opts to halt its advancement would jump ahead like Level A ACOs would move to Level C or Level D but would not have the necessary experience for succeeding in a level with higher risk.

Expansion for Telehealth reimbursement

This new proposed PFS rule would make permanent certain telehealth and workforce flexibilities provided during the COVID-19 public health emergency (PHE).

In the rise of the covid-19 pandemic in the US, policymakers have realized the severity and quickly relaxed long-standing healthcare regulations. This relaxation includes telemedicine reimbursement and healthcare fraud prevention laws.

MGMA has asked CMS for coverage for audio-only mental health services hence in the proposed rule, CMS has given importance to telehealth reimbursement expansion for mental and behavioral services by allowing expansion of telehealth reimbursement for certain services through the Medicare Physician Fee Schedule in 2022.

CMS is proposing to permanently add several of those services to the Medicare telehealth services list on a Category 1 and Category 3 basis for CY 2021 and this step of CMS is a hope of delight for every physician. Moreover, CMS also floated allowing certain services that were added to the Medicare telehealth list during the pandemic to remain there at least until the end of 2023.

Office/Outpatient Evaluation and Management (E/M) Visits

CMS is proposing to adopt the actual total times instead implement in CY 2021 the RUC-recommended total times finalized in the CY 2020 final rule for CPT codes 99202 through 99215 (defined as the sum of the component times).

Merit-Based Incentive Payment System (MIPS) and its value pathways

For the 2023 payment year, CMS is proposing to reduce the MIPS performance threshold and include a total of 206 quality measures starting in the performance year 2021. up to 20 % of MIPS eligible clinician’s final score for the 2023 MIPS payment year will be made by the Cost performance category.

Moreover, In the proposed rule the guiding principles, development criteria, and process for the MIPS Value Pathways (MVPs) are updated to guide implementation beginning with the 2022 MIPS performance period/2024 MIPS payment year.

In conclusion, you will find mixed reactions from various healthcare leaders on the CY 2022 Medicare Physician Fee Schedule proposed rule as industry groups are already criticizing by identifying benefits of policies to the physicians’ practices. If you are looking for Medical billing company which takes care of dynamism about healthcare industry and making reimbursement an easy process, then you can get in touch with us.

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