The Centers for Medicare & Medicaid Services (CMS) has released the final rule for the 2022 Medicare physician fee schedule. This rule includes updates to payment rates for 2022; expands the use of telehealth for mental health; and makes changes to policies for the 2022 performance year of the Quality Payment Program; among many other provisions.

Notably, the 2022 Medicare conversion factor will be reduced by approximately 3.85% from 34.8931 (2021) to 33.5983 (2022). This is due in part to the expiration of the 3.75% payment increase provided by the Consolidated Appropriations Act of 2021. The California Medical Association (CMA) urged CMS to mitigate the impact of the looming Medicare payment cuts, but the agency moved forward with the conversion factor reduction. The remainder of the Medicare payment cuts do not fall under the purview of CMS, and must be addressed by Congress.

CMA is still reviewing and analyzing the rule, but we wanted to share highlights of key changes and policies. We will provide a detailed summary in the coming days.

 Telehealth Services

• Certain Medicare telehealth services list will remain on the list through December 31, 2023.
• CMS has implemented statutory requirements to remove geographic restrictions and add the home of the beneficiary as a permissible originating site for telehealth services furnished for the purposes of diagnosis, evaluation or treatment of a mental health disorder.
• CMS is limiting the use of audio-only telehealth to mental health services furnished by practitioners who have the capability to furnish two-way, audio/video communications, but where the beneficiary is not capable of, or does not consent to, the use of two-way, audio/video technology.

Physician Assistants

• Beginning January 1, 2022, physician assistants (PAs) may bill Medicare directly for their professional services, reassign payment for their professional services, and incorporate with other PAs and bill Medicare for PA services. 

Vaccine Administration

• CMS will pay $30 per dose for the administration of the influenza, pneumococcal and hepatitis B virus vaccines.
• CMS will maintain the current payment rate of $40 per dose for the administration of the COVID-19 vaccines through the end of the calendar year in which the ongoing public health emergency (PHE) ends. Effective January 1 of the year following the year in which the PHE ends, the payment rate for COVID-19 vaccine administration will be set at a rate to align with the payment rate for the administration of other Part B preventive vaccines.

Quality Payment Program

• Transition to the Merit-Based Incentive Payment System (MIPS) Value Pathways (MVPs) will not occur until the 2023 performance year.

• The seven MVPs for the 2023 performance year are: rheumatology, stroke care and prevention, heart disease, chronic disease management, emergency medicine, lower extremity joint repair and anesthesia.

• CMS is allowing MIPS eligible clinicians to report the APM Performance Pathway as a subgroup, beginning with the 2023 performance year.
• The performance threshold for the 2022 performance year/2024 payment year will be set at 75 points, which is an increase of 15 points from the previous year.

• The additional performance threshold will be set at 89 points.
• For individuals, groups, and virtual groups reporting traditional MIPS, quality will be weighted at 30%, cost at 30%, promoting interoperability at 25% and improvement activities at 15%.
• CMS finalized its proposal to extend the CMS Web Interface as a quality reporting option for registered groups, virtual groups or other APM Entities for the 2022 performance period.
• CMS will be maintaining the 70% data completeness requirement in the 2023 performance period in response to stakeholder comments.

For more information:

• 2022 Physician Fee Schedule Final Rule
• CMS 2022 Physician Fee Schedule Fact Sheet