On September 13, the AACU submitted a formal comment letter to the Centers for Medicare and Medicaid Services (CMS) on the proposed CY 2022 Medicare Physician Fee Schedule (PFS). The rule proposes Medicare payment and policy changes for 2022, including several proposals which could significantly impact Urology:
Practice Expense — Update to Clinical Labor Rates
For 2022, CMS proposed an update to clinical labor rates — the first in 20 years — that will dramatically impact practice expense RVUs for several urology codes. Coupled with a 3.75% cut to the Medicare conversion factor and other reductions, some services provided by urologists may be reimbursed as much as 10% less in 2022 than in 2021.
Valuation of Specific Codes
Among proposed new or revised valuations of CPT and HCPCS codes are codes utilized primarily by urologists, such as 53855 (temporary prostate stents), 52441-52442 (cystourethroscopy), and 53XX1-53XX4 (periurethral balloon continence device procedures). The AACU commented on all of these codes and for some requested that CMS review the underlying practice costs and revise the practice expense RVU based on data provided.
Evaluation and Management Visits
The AACU voiced its support for E/M changes implemented earlier this year that allow physicians to select the E/M visit level based on either the total time spent with patients during their visit or the medical decision making (MDM) associated with a patient visit. The letter noted some concerns, however, regarding guidance related to visits split or shared by a physician and a non-physician clinician working in the same group.
Telehealth
Consistent with AACU’s long-standing position, the association urged CMS to permanently lift statutory geographic and originating site restrictions on telehealth technologies so that all Medicare beneficiaries have access to telehealth services regardless of where they live. In addition, AACU’s letter expressed disappointment that CMS did not add several urology-specific services to the Medicare Telehealth Services List for 2022.
Quality Payment Program
The AACU provided detailed feedback on how MIPS Value Pathways (MVPs) will be implemented and encouraged CMS to work with the Urology community, including AACU, on developing a urology-specific MVP that reflects the nature of our specialty, alleviates burdensome reporting requirements, and removes barriers that inhibit small and independent practices from participating. The letter also urged CMS to finalize its proposals to increase the MIPS performance threshold from 60 to 75 points and raise the additional performance threshold from 85 to 89 points, which will help justify the compliance obligations associated with participation in the MIPS program.
AACU will continue to advocate on behalf of the Urology community over the coming months by urging CMS and Congress to work together to avert impending payment decreases that could severely impact physician practices in 2022.
Read The Full Letter