The Centers for Medicare & Medicaid Services (CMS) annually updates the Medicare physician fee schedule (MPFS) for the upcoming calendar year. The regulatory update addresses physician payment and coverage for services under Medicare Part B and the Quality Payment Program through revisions to payment policies, rates, and other provisions, including geographic adjustments and the relative value units (RVUs) assigned to services. RVUs assigned to each code reflect the physician work, practice expense (PE), and professional liability insurance involved in furnishing that service.
2022 Medicare Payment Rates and Conversion Factor
CMS released the calendar year 2022 MPFS final rule in November. The AAFP summarized the final rule for members. Following the Academy’s comprehensive comments on the proposed rule, the final rule included several notable wins for family medicine. However, the 2022 Medicare conversion factor is about 3.75% lower than the 2021 conversion factor because the increase that Congress implemented for 2021 will expire on Dec. 31, 2021. The AAFP is urging Congress to increase the 2022 conversion factor to avert cuts for physicians. Without congressional action, family medicine will see a reduction in allowed charges in 2022.
In the final rule, CMS implements a long-overdue increase in clinical labor pricing, one component factored into PE RVUs, which has not been updated since 2002. CMS will update clinical labor pricing to reflect current wages and the cost of benefits, ensuring that physician practices can hire and retain nurses, medical assistants, and other vital clinical staff.
Other Changes in the CY 2022 MPFS
CMS will permanently cover audio/video and audio-only tele–mental health services for all beneficiaries in their homes after the end of the public health emergency. The AAFP supported this change and is pleased that it will also apply to federally qualified health centers and rural health centers.
With support from the AAFP, the agency will also increase the value of chronic care management codes in 2022.
In response to ongoing AAFP advocacy, CMS will nearly double Medicare payment rates for routine vaccine administration beginning in 2022.
CMS will automatically apply the Merit-based Incentive Payment System (MIPS) extreme and uncontrollable circumstances policy for the 2021 performance period. The AAFP lobbied for this policy to be automatically applied to provide physicians reporting relief from the ongoing COVID-19 pandemic.
CMS will implement a new MIPS reporting option, MIPS Value Pathways (MVPs), beginning in performance year 2023. MVPs are meant to be a more meaningful, less burdensome way to report under MIPS. The agency also finalized an MVP focused on chronic disease management, which may be a useful reporting option for family physicians in the future.
You can find a comprehensive summary of the final rule here. The changes for CY 2022 will go into effect on Jan. 1, 2022.
Why We Fight
More than 90% of family physicians accept Medicare. The MPFS is also often the basis for payment schedules used by other payers, including TRICARE, state Medicaid plans, and many private payers. What happens with the MPFS therefore has an enormous impact on primary care. Yet the annually updated MPFS does not necessarily advance a primary care–centered health system that improves health and reduces system costs.
As a result of the AAFP’s staunch advocacy, family medicine practices will see improved payments in 2022 for vital services such as vaccine administration and chronic care management, as well as improved Medicare coverage policies for tele-mental health for years to come. The Academy’s advocacy on the MPFS has also been successful at reducing reporting requirements and lessening physicians’ administrative burden.
CMS has adopted policies to increase values for office visit/outpatient Evaluation and Management (E/M) services and updated office visit/outpatient E/M coding and documentation guidelines. The new values and guidelines went into effect Jan. 1, 2021. These changes were a direct result of years of lobbying by the AAFP and amounted to a significant increase in Medicare payment for family medicine — a long-sought raise for family physicians. To the extent that other payers rely on the MPFS, family physicians may experience a payment increase beyond Medicare. In comments on the CY 2022 MPFS proposed rule, the AAFP strongly urged CMS to help ensure that these increases would be passed on to employed physicians.
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