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CY 2022 Final Rule Summary for Anesthesia
Anesthesia Conversion Factors
The Medicare National Anesthesia Conversion Factor (CF) dropped from $21.56 to $20.93 (-2.9%). The Medical/Surgical Conversion Factor used to price non-time-based services dropped from $34.89 to $33.60 (-3.7%). Should these values remain unchanged without Congressional intervention, they’ll have a negative impact on not only your 2022 Medicare collections, but also on your private payer collections, if your fee schedules are tied to a percentage of Medicare.
Anesthesia for cardiac electrophysiologic procedures, including radiofrequency ablation (CPT code 00537)
CMS approved an increase in base units for the above-mentioned procedure, from 7 to 10. This change is effective for dates of service 1/1/22 forward. This is good news for groups providing anesthesia for EP procedures and is consistent with the ASA Relative Value Guide’s current base units for the service.
Anesthesia Services for Image Guided Spinal Procedures (CPT codes 01937, 01938, 01939, 01940, 01941, and 01942)
CMS replaced codes 01935 (Anesthesia for percutaneous image guided procedures on the spine and spinal cord – 5 base units) and 01936 (Anesthesia for percutaneous image guided procedures on the spine and spinal cord; therapeutic – 5 base units), with the following 6 new codes. This change is effective for dates of service 1/1/22 forward and applies to all payers.
- 01937 (Anesthesia for percutaneous image-guided injection, drainage or aspiration procedures on the spine or spinal cord; cervical or thoracic) 4 base units
- 01938 (Anesthesia for percutaneous image guided injection, drainage or aspiration procedures on the spine or spinal cord; lumbar or sacral) 4 base units
- 01939 (Anesthesia for percutaneous image guided destruction procedures by neurolytic agent on the spine or spinal cord; cervical or thoracic) 4 base units
- 01940 (Anesthesia for percutaneous image guided destruction procedures by neurolytic agent on the spine or spinal cord; lumbar or sacral) 4 base units
- 01941 (Anesthesia for percutaneous image guided neuromodulation or intravertebral procedures (eg. Kyphoplasty, vertebroplasty) on the spine or spinal cord; cervical or thoracic) 5 base units
- 01942 (Anesthesia for percutaneous image guided neuromodulation or intravertebral procedures (eg. Kyphoplasty, vertebroplasty) on the spine or spinal cord; lumbar or sacral) 5 base units
Anesthesia for Screening Colonoscopy converted to a diagnostic/therapeutic procedure
CMS agreed to phase in a plan that would reduce patients’ out-of-pocket expenses for screening colonoscopies converted to polypectomies, as specified below:
- CY 2022: 80% Medicare coverage, 20% Patient coinsurance
- CY 2023-2026: 85% Medicare coverage, 15% Patient coinsurance
- CY 2027-2029: 90% Medicare coverage, 10% Patient coinsurance
- CY 2030 and beyond: 100% Medicare coverage, 0% Patient coinsurance
MIPS
As expected, CMS eliminated the bonus point system for high priority MIPS measures. In practical terms, this means that groups reporting through Qualified Registries
(QRs) on national MIPS measures 44, 76, 404, 424, 430, 463 and 477 will (at best) barely escape a penalty for reporting year 2022 and definitely miss out on any bonus money. To combat this issue, practices are encouraged to look at Qualified Clinical Data Registries (QCDRs) instead, which have more highly weighted MIPS measure options to choose from. MSN Healthcare Solutions has a QCDR with 14 anesthesia-specific measures for groups to consider.
CMS will offer a new way for anesthesia providers to report MIPS in CY 2023, called MIPS Value Pathways or “MVPs” (more information forthcoming). For CY 2022, the following changes were made, affecting traditional MIPS composite scoring for practices:
- Quality performance category: 30% (-10% from 2021)
- Cost performance category: 30% (+10 from 2021)
- Improvement Activities performance category: 15% (Unchanged)
- Promoting Interoperability performance category: 25% (Unchanged)
- Composite score performance threshold to avoid a penalty: 75 (+15)
- Composite score exceptional performance threshold to achieve a bonus: 89 points (+4)
- Data completeness criteria threshold: 70% (Unchanged)
Inpatient Only List
Last year, CMS removed more than 200 surgical codes from their Inpatient Only (IPO) list, thus allowing payment for such procedures in outpatient settings, like ASCs. This was supposed to have been part of a three-year plan which would ultimately eliminate the IPO list entirely. Due to lobbying efforts, CMS reversed course for CY 2022. They have decided to shelve the plan and are adding all but 3 of these surgical codes back onto the IPO list. The end result is that the following 22 ASA crosswalk codes will no longer be payable in ASC settings, beginning 1/1/22:
- 00192 Anesthesia for procedures on facial bones or skull; radical surgery (including prognathism)
- 00474 Anesthesia for partial rib resection; radical procedures (e.g., pectus excavatum) 00604 Anesthesia for procedures on cervical spine and cord; procedures with patient in the sitting position
- 00904 Anesthesia for; radical perineal procedure
- 0095T Removal of total disc arthroplasty (artificial disc), anterior approach, each additional interspace, cervical
- 0098T Revision including replacement of total disc arthroplasty (artificial disc), anterior approach, each additional interspace, cervical
- 01140 Anesthesia for interpelviabdominal (hindquarter) amputation
- 01150 Anesthesia for radical procedures for tumor of pelvis, except hindquarter amputation
- 01212 Anesthesia for open procedures involving hip joint; hip disarticulation
- 01232 Anesthesia for open procedures involving upper two thirds of femur; amputation
- 01234 Anesthesia for open procedures involving upper two thirds of femur; radical resection
- 01274 Anesthesia for procedures involving arteries of upper leg, including bypass graft; femoral artery embolectomy
- 01404 Anesthesia for open or surgical arthroscopic procedures on knee joint; disarticulation at knee
- 0163T Total disc arthroplasty (artificial disc), anterior approach, including discectomy to prepare interspace (other than for decompression)
- 01634 Anesthesia for open or surgical arthroscopic procedures on humeral head and neck, sternoclavicular joint, acromioclavicular joint, and shoulder joint; shoulder disarticulation
- 01636 Anesthesia for open or surgical arthroscopic procedures on humeral head and neck, sternoclavicular joint, acromioclavicular joint, and shoulder joint; interthoracoscapular (forequarter) amputation
- 0164T Removal of total disc arthroplasty, (artificial disc), anterior approach, each additional interspace, lumbar
- 0165T Revision including replacement of total disc arthroplasty (artificial disc), anterior approach
- 01756 Anesthesia for open or surgical arthroscopic procedures of the elbow; radical procedures
- 0202T Posterior vertebral joint(s) arthroplasty (for example, facet joint[s] replacement), including facetectomy, laminectomy, foraminotomy, and vertebral column fixation, injection of bone cement, when performed, including fluoroscopy, single level, lumbar spine
- 0219T Placement of a posterior intrafacet implant(s), unilateral or bilateral, including imaging and placement of bone graft(s) or synthetic device(s), single level; cervical
- 0220T Placement of a posterior intrafacet implant(s), unilateral or bilateral, including imaging and placement of bone graft(s) or synthetic device(s), single level; thoracic
*The following two anesthesia codes were originally slated to be added back onto the IPO list, but were excluded in the Final Rule. This is good news for anesthesia groups working in Ortho ASCs.
- 01486 Anesthesia for open procedures on bones of lower leg, ankle, and foot; total ankle replacement
- 01638 Anesthesia for open or surgical arthroscopic procedures on humeral head and neck, sternoclavicular joint, acromioclavicular joint, and shoulder joint; total shoulder replacement
Hal has 30+ years of experience on both the payor and RCM side, with a focus in Anesthesia. He formerly worked as a senior claims approver at United Healthcare, as well as a compliance officer for multiple national anesthesia billing companies. His broad-based experience ensures that MSN clients have a resource for documentation and billing issues. His past speaking engagements include ASA, MGMA, Dartmouth, and Johns Hopkins.
