CMS releases 2022 Medicare physician fee schedule and QPP proposals

The Centers for Medicare & Medicaid Services (CMS) has released its proposed rule on the 2022 Medicare Physician Fee Schedule and Quality Payment Program (QPP).

Highlights related to the fee schedule include:

• CMS proposes to retain everything temporarily added to the Medicare telehealth services list through 2023.
• CMS proposes to increase the work relative value units (RVUs) for each of the chronic care management codes.
• CMS acknowledges Medicare payments for vaccine administration services have become increasingly insufficient and seeks detailed comments on the cost of vaccine supplies and administration to create a new, more sustainable payment structure.
• CMS proposes to delay full implementation of the Appropriate Use Criteria for Diagnostic Imaging program until Jan. 1, 2023, or Jan. 1 in the year after the COVID-19 public health emergency ends, whichever is later.

Highlights related to QPP include:

• CMS proposes to add five new episode-based cost measures, including two chronic condition episodes, to the “Cost” category of the Merit-based Incentive Payment System.
• Beginning with the 2022 performance period, CMS proposes to no longer require clinicians and small practices seeking reweighting of the Promoting Interoperability category to apply for hardship exemptions. For practices with 15 or fewer eligible clinicians, CMS would automatically assign a weight of zero to the category and redistribute its weight to other performance categories.
• CMS proposes to modify the complex patient bonus to better target eligible clinicians who treat more complex and high-risk patients.

The bad news is that CMS proposes to decrease what it pays per RVU (i.e., the conversion factor) in 2022. CMS proposes to set the 2022 conversion factor at $33.58, or 3.75% lower than this year. The decrease is due to the expiration of a 3.75% increase that Congress applied in December 2020. A coalition of medical groups, including the American Academy of Family Physicians, is advocating for a legislative remedy to prevent the cut. 

A broader summary of the CMS proposals also highlights coverage improvements for mental health telehealth services. This summary from the AAFP contains more information as well.

— Kent Moore, Senior Strategist for Physician Payment