Practice: CMS Releases Proposed Updates to Physician Fee Schedule and the Quality Payment Program

On July 13, 2021, the Centers for Medicare & Medicaid Services (CMS) issued a proposed rule that includes updates to payment policies, payment rates and quality provisions for services furnished under the Medicare Physician Payment Schedule effective on or after January 1, 2022. AANEM policy staff is diligently reviewing the 1,700+ page rule but here are a few highlights from the proposal:
 

• A significant 3.75% reduction in the Medicare conversion factor – the proposed conversion factor for 2022 is $33.58, a decrease of $1.31 from the 2021 conversion factor of $34.89. This proposed decrease is due to the budget neutrality adjustment that will be required in 2022 to offset the payment increases for office visits.  AANEM will be working with the AMA and other specialty societies to advocate that the budget neutrality adjustment must continue to be waived in light of the continued COVID-19 public health emergency (PHE).
• CMS is proposing to refine its policies for split or shared E/M visits to reflect the evolving role of non-physician practitioners (NPPs) as members of the medical team.
• CMS continues to evaluate the temporary expansion of telehealth services that were added to the telehealth list during the COVID-19 PHE.   CMS is proposing to allow certain services added to the Medicare telehealth list to remain on the list until December 31, 2023 to allow time to collect data and evaluate whether the services should be permanently added to the telehealth list.
• For MIPS, CMS is proposing to increase the 2022 performance threshold to 75 points from 60 points, as well as the exceptional performance bonus to 89 points from 85.  CMS is proposing to remove several bonus point opportunities, including for reporting additional outcome and high priority measures, and for meeting end-to-end electronic reporting criteria.  The rule also extends various flexibilities such as automatically reweighting the MIPS Promoting Interoperability performance category for all clinicians in small practices and continuing its doubled bonus point opportunities to reward caring for complex patients during the COVID-19 health emergency.
• The rule proposes seven MIPS Value Pathways (MVPs), which is a new track of the QPP that intends to offer more cohesive sets of MIPS measures and activities related to a specialty or condition.  CMS proposes voluntary reporting for MVPs to begin in 2023.

 
Once AANEM staff is finished reviewing the rule, they will work with the AANEM Board of Directors to craft a comment letter on the proposal which will be shared with membership via a Spark story in the next couple of months. For a comprehensive comparison of the current RVU’s with the proposed 2022 values for the codes relevant to EDX and NM medicine, please visit our website here.  If you have questions or concerns about the proposed rule, you can email the policy department at policy@aanem.org.