2022 Medicare Physician Fee Schedule

2022 Medicare physician fee schedule
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The 2022 Medicare Physician Fee Schedule
and Its Impact on Radiology

The Centers for Medicare and Medicaid Services (CMS) released the CY 2022 Payment Policies under the Physician Fee Schedule on November 2, 2021 and confirmed a decrease in the conversion factor from $34.89 to $33.58.

In addition, a new evaluation and management (E/M) code (G2211 — complex visit add-on code) will continue to be blocked from implementation (2021 was the first of three years).

Protecting Medicare and American Farmer from Sequester Cuts Act

However, on December 10, the President signed into law S. 610, the “Protecting Medicare and American Farmers from Sequester Cuts Act,” which delays Medicare sequestration and makes other changes to Medicare payments.

The bill extends the sequestration moratorium through March 31, 2022 and then adjusts the sequester from -2% to -1% from April 1 through June 30, 2022. The -2% sequestration is then reactivated for the remainder of 2022, from July 1 through December 31.

The planned recovery of the suspension of these payment reductions is a -2.25% sequestration from January 1 through June 30, 2030, which increases to -3% from July 1 through December 31, 2030.

The conversation factor will increase by 3% for calendar year 2022, which will yield higher payments under the Physician Fee Schedule. Other changes include a delay in the implementation of the Radiation Oncology Model until 2023 and a waiver of the statutory PAYGO requirement until 2023. 

Changes Impacting Payments to Physicians

Other changes that will impact payments to physicians in 2022 include: 

  • a) changes in relative value units (RVUs) resulting from the misvalued code initiative, including RVUs for new and revised codes;
  • b) the impact of CMS clinical labor pricing updates; and
  • c) the phase-in of previously finalized updates to supplies (6) and equipment (2) pricing.

Physician Assistants Authorized to be Paid Directly by Medicare

Section 403 of the Consolidated Appropriations Act, 2021 removes the requirement that payment for Physician Assistant (PA) services must be made to the PA’s employer only. This change was achieved through amending section 1842(b)(6)(C)(i) of the Social Security Act.

 Effective January 1, 2022, PAs are authorized to bill Medicare and to be paid directly for their services.
In addition, PAs may: 

  • a) reassign their rights to payment for their services and
  • b) incorporate as a group comprised solely of PAs and bill Medicare.

This amendment does not change a PA’s physician supervision requirements or the statutory payment percentage that applies to PA services.

Appropriate Use Criteria: Payment Penalty Phase

CMS has finalized the payment penalty phase for the Appropriate Use Criteria (AUC) program as the latter of January 1, 2023 or the January 1 that follows the declared end of the Public Health Emergency (PHE) for COVID-19. This flexibility is intended to take into consideration the impact of COVID-19 on both providers and beneficiaries.

Split E/M Visits: CMS Polices Refined

The CMS policies for split (shared) E/M visits have been refined to better reflect current practice and to recognize the evolving role of non-physician practitioners.The conditions of payment that must be met are also clarified.

The definition of a split E/M visit is one that is provided in a facility setting by both a physician and a non-physician practitioner in the same group. The provider who provides the “substantive” portion of the visit, defined as more than one-half of the total time spent, is to bill for the visit and must sign and date the medical record.

Medicare Telehealth Services

CMS received several requests to make permanent additions to the Medicare telehealth services list, effective in calendar year 2022. However, it was determined that none of the services met the criteria for Category 1 or Category 2 services for permanent addition.

CMS has also created a third category of criteria for adding to the telehealth services list on a temporary basis because of COVID-19.

Category 3 Telehealth Services

Category 3 telehealth services include services CMS believes are likely to provide clinical benefit when furnished via telehealth, but there is insufficient evidence to be included as a Category 1 or 2 service.

Services on the Category 3 telehealth list will be temporary and will remain on the telehealth services list through the end of the calendar year in which the COVID-19 PHE ends.

Due to stakeholder concerns about the uncertainty of when the PHE will end, CMS will retain all services added on a Category 3 basis until the end of CY 2023.

CMS is soliciting comment on whether any services added to the Medicare telehealth list for the duration of the PHE for COVID-19 should be added to the Medicare telehealth list on a Category 3 basis.

Miscellaneous

 

  • CMS accepted an increased value for needle biopsy of lymph nodes and has approved values for the new, trabecular bone score code family.

  • CMS has removed the National Coverage Determination (NCD) for Positron Emission Tomography (PET) scans (NCD 220.6) and will defer coverage decisions to local Medicare Administrative Contractors (MACs). CMS believes allowing local contractors the discretion to consider coverage will allow Medicare beneficiaries greater access to PET scans for non-oncologic indications.

  • Virtual Direct Supervision through Real-Time Audio/ Video Technology
    » CMS continues to seek comment on whether the flexibility to meet the “immediately available” requirement for direct supervision, which is being used during the PHE, should be made permanent. CMS did not finalize the decision for 2022.
Barbara Rubel MBA, FRBMA Senior Vice President, Marketing & Client Services

Barbara Rubel MBA, FRBMA Senior Vice President, Marketing & Client Services

Barbara has been a leader with MSN Client Services since 1998. Her extensive background in strategic planning, market research, healthcare marketing and managed care negotiations provides a wealth of information to support MSN Clients.

Barbara has also been highly involved in industry organizations, serving as President of the Radiology Business Management Association (RBMA), the Georgia RBMA, and the Florida RBMA. In addition, she chaired the influential RBMA Federal Affairs Committee and the RBMA Technology Task force and was a member of the RBMA Data Committee. Her work on behalf of radiology has earned her the RBMA Special Recognition Award (2010), the RBMA Global Achievement Award (2013), and she is a Fellow of the RBMA.