CMS Releases Medicare Physician Fee Schedule Proposed Rule

July 15, 2021

The Centers for Medicare & Medicaid Services (CMS) released the proposed rule for the calendar year 2022 (CY 2022) physician fee schedule on July 13. The key provisions in the proposed rule include a cut to the conversion factor to $33.58 in CY 2022, from $34.89 in CY 2021, reflecting the expiration of the 3.75% payment increase, a 0% conversion factor update and a budget neutrality adjustment. The proposed rule also includes proposals to expand access to telehealth for mental health services and delayed implementation of the payment penalty phase of the Appropriate Use Criteria program. For the Quality Payment Program, CMS proposes to offer seven optional Merit-based Incentive Payment System Value Pathways (MVPs) beginning in 2023. CMS also proposes to increase the Merit-based Incentive Program System (MIPS) performance threshold score clinicians and groups must exceed to receive positive payment adjustments. 

WHA has been tracking, in particular, the telehealth proposals. The Consolidated Appropriations Act of 2021 removed geographic restrictions on telehealth behavioral health services and allowed them to be delivered to a patient’s home. CMS is proposing to implement that, along with requirements for regular in-person contact with a provider. CMS is also proposing to continue allowing audio-only telehealth, while including a modifier code noting that a provider had the capability to do audio/video telehealth but that the service was provided via audio due to patient choice or limitations.

Comments on the proposed rule are due Sept. 13. 

This story originally appeared in the July 15, 2021 edition of WHA Newsletter