A proposed change to Medicare’s payment formula under the 2022 physician fee schedule, if implemented, would mean a modest payment cut for some physicians. However, the fee schedule proposal – coming in this year at a crisp 1,747 pages – includes what would be significant changes to telehealth in Medicare, among other provisions.
The Texas Medical Association is analyzing the proposed regulation and its impacts in detail and will submit comments to the Centers for Medicare & Medicaid Services (CMS) by the agency’s Sept. 7 deadline.
The draft rule, released last week, lowers the conversion factor that contributes to determining physician payments by 3.75% compared with the 2021 formula.
On telehealth, CMS proposes to:
- Require a physician delivering mental health services via telehealth to see a patient in person within six months prior to the initial telehealth visit, and at least once every six months after the initial telehealth visit;
- Allow audio-only visits for the diagnosis, evaluation, and treatment of mental health disorders for established patients in their homes; and
- Allow certain services that were added to the Medicare telehealth list for the COVID-19 public health emergency to stay on the list through 2023, and after the public health emergency, CMS would evaluate whether those services will stay on the list permanently.
Among other important pieces, the draft rule shows CMS listened to TMA on the appropriate use criteria program, an effort to cut down on overutilization of advanced imaging tests. As requested by TMA in late 2020, CMS proposes to delay issuing penalties for the program. Under the rule, the penalty phase would start either at the beginning of 2023 or the beginning of the calendar year that follows the end of the public health emergency, whichever is later.
The proposal also contains a special coinsurance rule for planned colorectal cancer screening tests that become diagnostic tests once the test uncovers a need for other services. That recommendation would implement last year’s Consolidated Appropriations Act, which gradually reduces the coinsurance amount for patients who undergo such tests, dropping it all the way to zero at the beginning of 2030.
As usual, the proposed rule also includes adjustments to Medicare’s Quality Payment Program (QPP) and its Merit-Based Incentive Payment System (MIPS). Among the notable changes, CMS’ proposed performance threshold for MIPS in 2022 is 75 points, the mean final score from the program’s first year in 2017. That would be an increase of 15 points from this year’s performance threshold.
As TMA continues to analyze the fee schedule, here are fact sheets CMS has released for both the fee-schedule proposal in general and the QPP-related parts of the rule.
Last Updated On
July 21, 2021
Originally Published On
July 21, 2021