Pay Cut In Proposed 2022 CMS Physician Fee Schedule?

The proposed 2022 Medicare Physician Fee Schedule and Quality Payment Program rules released by CMS have a lot of changes, but the most important one is the 3.75% reduction in the conversion factor used to calculate payments to physicians.

The proposed cuts are the result of a reduction that is necessary to keep Medicare payments budget neutral. At the end of 2020, Congress passed a one-year fix that prevented the cuts due to take effect in 2021. The original reduction in the conversion factor was put in place by CMS to accompany the 2021 reevaluation of evaluation and management codes for office visits. Without additional intervention, the cuts will go into effect Jan. 1, 2022.

Multiple organizations are lobbying for Congress to prevent the proposed reduction from going into effect, due to the severe financial impact of the ongoing COVID-19 pandemic on physicians.

Other proposed changes to the 2022 Physician Fee Schedule include an extension of Medicare coverage for some “Category 3” telehealth services. Currently, coverage of these particular codes is due to sunset at the end of the Public Health Emergency (PHE). The extension would last through the end of 2023 to allow CMS time to gather data on utilization and medical necessity.

At a time when the mental health impacts of the ongoing pandemic are becoming increasingly clear, the proposal that some mental health care services can be provided on an audio-only basis are of interest. The proposed rule would remove geographic restrictions for diagnosis, evaluation, or treatment of a mental health disorder. It would also remove the originating site of service restriction currently in place, allowing the patient’s home to serve as the originating site. It does require that the patient have had an in-person visit within six months prior to the telehealth visit.

The full proposal can be found at the Federal Register, and a summary of additional changes may be found here.