FY2022 Physician Fee Schedule Is Released

Gloryanne Bryant, RHIA, CDIP, CCS, CCDS Profee Coding Leave a Comment

FY2022 Physician Fee Schedule Is Released

On November 2nd, 2021, the Centers for Medicare, and Medicaid Services (CMS) released their 2022 Physician Fee Schedule (PFS) final rule, which is 2,414 pages in length. Included in this policy ruling was also some other Medicare Part B issues. The PFS rule making is part of the Biden Administration strategy of better accessibility, quality, affordability, empowerment, and innovation. The changes made for FY2022 are effective on January 1, 2022.

The PFS has been in place since 1992 and covers services of physicians and other billing professionals. CMS makes payment for Physicians’ services paid under the PFS that are furnished in a variety of settings; including physician offices, hospitals, ambulatory surgical centers (ASCs), skilled nursing facilities and other post-acute care settings, hospices, outpatient dialysis facilities, clinical laboratories, and beneficiaries’ homes. Payment is also made to several types of suppliers for technical services, generally in settings for which no institutional payment is made.

The physician fee schedule “conversion factor” is used to determine provider reimbursement will drop to $33.59 in 2022 from $34.89 this year as a temporary payment boost provided by the Consolidated Appropriations Act expires. 

Under the FY2022 PFS, CMS is amending the definition of interactive telecommunications system for telehealth services to include audio-only communications technology used to diagnose, evaluate, or treat mental health disorders in certain cases. CMS also clarified that mental health services can include treatment of substance use disorders. 

The PFS final rule will increase or nearly double Medicare Part B payment rates for certain vaccines, including influenza, pneumonia and hepatitis B. CMS said hopes this increase in payment rates — from $17 to $30 — will improve access and lead to greater vaccination uptake. 

For 2022 “Evaluation and Management”: For 2022, CMS is making a number of refinements to current policies for split or shared E&M visits, critical care services and services furnished by teaching physician involving residents.

  • The definition of split or shared E&M visit as E&M visit provided in the facility setting by a physician and a Non-Physician Practitioner (NPP) in the same group. The visit is to be billed by the physician or practitioner who provide the substantive portion of the visit.
  • In addition, CMS stated that split E&M services can be reported for a new as well as established patients, and initial and subsequent visits, as well as prolonger services.
  • Note a modifier is required on the claim to identify these services to inform policy and ensure program integrity.
  • Documentation in the medical record must identify the two individuals who performed the E&M visit. The individual providing the substantive portion must sign and date the medical record.

In addition, CMS is some refinements to the Critical Care CPT usage (review the full guidance from CMS):

  • Critical care services are defined in the CPT codebook refractory language for the code set.
  • The CPT codebook listing of bundled services are not separately payable.
  • When medically necessary, critical care services can be furnished concurrently to the same patient on the same day by more than one practitioner representing more than one specialty, and critical care services can be furnished as split (or shared) visits.
  • Critical care services may be paid on the same day as other E&M visits by the same practitioner or another practitioner in the same group of the same specialty, if the practitioner documents that the E&M visit was provided prior to the critical care service at a time when the patient did not require critical care, the visit was medically necessary, and the services area separate and distinct, with no duplicative elements from the critical care service provided later in the day. Practitioners must report modifier -25 on the claim when reporting these critical care services.

The 2022 rule also continues to promote more telehealth, especially in relation to behavior health, so this is an area to review carefully in order to have compliant documentation and coding. CMS will retain certain telehealth services added during the Public Health Emergency (PHE) to December 31, 2023. In this time CMS will be continuing to evaluate these services. According to the CMS press release, they will also extend the inclusion of certain cardiac and intensive cardiac rehabilitation codes through the end of CY 2023. Remember that during the COVID-19 PHE we’ll seen a large increase in telehealth services and use. However, there also has been some Office of Inspector General (OIG) compliance concerns, so make sure you are having this area audited soon for documentation and coding accuracy.

Billing for Physician Assistant (PA) Services: Beginning January 1, 2022, 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.

Administration of Preventive Vaccines: Beginning January 1, 2022, CMS will pay $30 per dose for the administration of the influenza, pneumococcal and hepatitis B virus vaccines. In addition, 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 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.

In-Home Administration of COVID-19 Vaccines: CMS will continue the additional payment of $35.50 for COVID-19 vaccine administration in the home under certain circumstances through the end of the calendar year in which the PHE ends.

CMS is also updating the clinical labor rates that are used to calculate practice expenses under the Physician Fee Schedule for the first time in nearly two decades. For FY2022 the payments to primary care specialists that involve more clinical labor, such as geriatrics and family practice, are expected to increase.

This PFS final rule is also encouraging growth of the CMS diabetes prevention program. With the increase of beneficiaries with type I and type II diabetes, the changes to the Medicare Diabetes Prevention Program or MDPP are welcomed. Per CMS these MDPP policies are intended to boost supplier enrollment, with the goal of increasing beneficiary participate and access to services. In addition, this will help beneficiaries develop and maintain healthy behavior’s to prevent onset of type 2 diabetes.

This blog does not cover nor provide ALL the PFS additions and revisions, for you’ll want to review the CMS fact sheet on the Physician Fee Schedule Final Rule, as there can be impact to operations, chargemaster, documentation, coding and billing, so go online to https://www.cms.gov/newsroom/fact-sheets/calendar-year-cy-2022-medicare-physician-fee-schedule-final-rule.

In addition, you can review all 2414 pages of the 2022 Physician Fee Schedule, go to  https://www.federalregister.gov/public-inspection/current.

There is a CMS fact sheet on changes made to the Medicare Diabetes Prevention Program, so be sure to visit: https://www.cms.gov/newsroom/fact-sheets/final-policies-medicare-diabetes-prevention-program-mdpp-expanded-model-calendar-year-2022-medicare

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