Billing, Coding and 2021 Payment Schedules

2022 Medicare Physician Fee Schedule Proposed Rule Released – Changes to Payment Rates, Telehealth - July 15, 2021


The Centers for Medicare & Medicaid Services (CMS) released the proposed rule for the 2022 Medicare physician fee schedule. It is open for comment until September 13, 2021. AMA and VMS staff continue to analyze the full proposal. Notably, the 2022 Medicare conversion factor would be reduced by approximately 3.89% from $34.8931 to $33.5848. This is largely a result of the expiration of a 3.75% increase to the conversion factor at the end of calendar year 2021, as averted for 2021 by Congressional action. The AMA will strongly advocate that Congress avert this significant cut and extend the 3.75% increase for 2022. Regarding telehealth access, CMS is proposing to retain a number of services added to the Medicare telehealth services list on a temporary basis through the end of December 31, 2023, so that there is a path to evaluate whether the services should be permanently added to the telehealth list following the COVID-19 public health emergency. CMS also proposes to implement recently enacted legislation that removes certain statutory restrictions to allow patients in any geographic location and in their homes access to telehealth services for diagnosis, evaluation, and treatment of mental health disorders and proposes to allow payment to eligible practitioners when they provide certain mental and behavioral health services to patients via audio-only telephone calls from their homes. For other audio-only services, CMS proposes to continue with their plan to end reimbursement for telephone codes 99441, 99442 and 99443 after the federal public health emergency ends but to permanently adopt coding and payment for HCPCS codes G2252 (extended virtual check in for 11–20 minutes of medical discussion) and reimburse at the same level as CPT 99442. The rule also proposes a number of other regulatory changes in areas including electronic prescribing of controlled substances for Medicare Part D, telehealth services offered by FQHCs and to the Medicare Shared Savings ACO program.The full text of the proposed rule can found at: https://public-inspection.federalregister.gov/2021-14973.pdf.CMS Press Release: https://www.cms.gov/newsroom/press-releases/cms-proposes-physician-payment-rule-improve-health-equity-patient-accessPhysician Fee Schedule Fact Sheet: https://www.cms.gov/newsroom/fact-sheets/calendar-year-cy-2022-medicare-physician-fee-schedule-proposed-ruleQPP Fact Sheet: https://qpp-cm-prod-content.s3.amazonaws.com/uploads/1514/2022%20QPP%20Proposed%20Rule%20Resources.zip

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