Last week, the Centers for Medicare and Medicaid Services (CMS) issued its annual proposed rule that updates payment rates for physicians under the Medicare Physician Fee Schedule (PFS) effective January 1, 2022. The rule also expands the use of telehealth, clarifies evaluation and management (E/M) policies, and proposes policies for the 2022 performance year of the quality payment program, among other provisions (proposed rule; fact sheet; press release).
AACU is still reviewing the 1,700-page proposed rule, but we have compiled below some of the key proposals in the rule, particularly as it relates to the urology community. We will share additional information on specific provisions in this year’s rule in the coming weeks.
Physician Fee Schedule Highlights:
- Conversion Factor: Reduces the Medicare conversion factor from $34.89 in CY 2021 to $33.58 for CY 2022, a decrease of 3.75%.
- Specialty Impacts: The combined impact of the rule and the conversion factor is an estimated -3.7% decrease in total allowed Medicare charges for Urology in CY 2022 (varies based on individual physician’s case mix).
- Resource-Based Relative Value Scale (RBRVS) Updates: No changes to urology codes under the RBRVS. Proposes RUC-recommended rates for 4 new periurethral adjustable balloon continence devices.
- E/M Polices: Clarifies and refines policies related to split (or shared) E/M visits, critical care services, and services furnished by teaching physicians involving residents. Does not increase the value of E/M post-operative services in 10- and 90-day global surgery codes.
- Appropriate Use Criteria Program (AUC): Postpones the payment penalty of the AUC program to Jan. 1, 2023 or the Jan. 1 that follows the declared end of the public health emergency (PHE), whichever is later.
- Medicare Shared Savings Program: Postpones for an additional two years the start of electronic quality reporting requirements for Accountable Care Organizations (ACOs) reporting MIPS data.
- Telehealth: Permits certain services added to the Medicare telehealth list to remain on the list until the end of 2023 while the agency evaluates whether these changes should be made permanent.
Quality Payment Program Highlights:
- Merit-based Incentive Payment System (MIPS): MIPS Value Pathways (MVPs) will go into effect, beginning with seven options, in 2023. CMS solicits feedback on its goal to sunset the traditional MIPS program after 2027.
- Performance Categories: For the 2022 performance year/2024 payment year, the performance category weights are: 30% for quality; 30% for cost; 15% for improvement activities; and 25% for promoting interoperability. The rule adds 5 new episode cost-measures to the cost category and revises reporting requirements for the promoting interoperability category.
- Performance Threshold: Proposes a performance threshold of 75 points.
The AACU will submit a formal comment letter on the proposed rule prior to CMS’ September 17, 2021 deadline. Please contact Yehuda Sugarman if you would like to provide feedback that we can incorporate into our comment letter.