2022 Physician Fee Schedule prompts praise, but also fear of ‘financial peril’
The CMS final rule regarding physician payment, clinical labor prices, critical care services and telehealth services for fiscal year 2022 has drawn mixed reactions from medical groups.
Some of the rule’s components exacerbate concerns brought on by the COVID-19 pandemic while others alleviate them, the groups said.
Gains, losses in physician payments
CMS said that the Medicare Part B rates physicians receive for each influenza, pneumococcal and hepatitis B vaccine administered will increase from approximately $17 to $30.
In addition, CMS said that the current payment physicians receive for each dose of the COVID-19 vaccine that they administer will remain $40 “through the end of the calendar year in which the ongoing [public health emergency] ends.” After this, the payment rate for each COVID-19 vaccine dispensed “will be set at a rate to align with the payment rate for the administration of other Part B preventive vaccines.”
CMS also finalized its proposal to allow rural health clinics and federally qualified health centers to bill for chronic care management services, including transitional care management, that are delivered “for the same beneficiary during the same service period, provided all requirements for billing each code are met.”
The American Academy of Family Physicians applauded these decisions.
“For decades, our primary care system has been strained, underfunded and understaffed — COVID-19 has only exacerbated these challenges. We’re pleased CMS has acknowledged this historic undervaluation and is again taking steps to address it by increasing payment rates for vaccine administration and chronic care management services,” AAFP President Sterling N. Ransone, Jr., MD, FAAFP, said in an academy statement.
ACP said that it is “extremely concerned about the across-the-board cuts to physician payments that will go into effect at the beginning of 2022.”
“The proposed cuts are the result of a statutorily-required reduction that is necessary to keep Medicare payments budget neutral,” ACP said in a statement released by the college.
Congress can stop the “financial peril” that physicians will face at the end of 2021, AMA President Gerald E. Harmon, MD, said in an association statement. Overall, there could be a 9.75% cut to Medicare physician payments for 2022, he said.
“This comes at a time when physician practices are still recovering the personal and financial impacts of the COVID public health emergency,” he added. “The AMA is strongly advocating for Congress to avert this.”
Ransone also encouraged Congress to “mitigate looming Medicare cuts that harm physician practices.”
ACP President George Abraham, MD, FACP, said it will be important “to ensure that practices across the country are able to continue to operate and provide frontline care that improves health equity and patient access in their communities.”
First labor price increase since 2002
The final rule also includes the first update in nearly 20 years to clinical labor rates that are used to determine practice expenses, CMS said. Many health care professionals will see increases in payment over the next 4 years for each minute they conduct tasks.
- opticians, who currently earn 33 cents per minute for certain tasks, will be paid 35 cents per minute next year and 39 cents per minute in 4 years;
- audiologists, who currently earn 52 cents per minute for certain tasks, will be paid 59 cents per minute next year and 81 cents per minute in 4 years;
- physical therapy assistants, who currently earn 39 cents per minute for certain tasks, will be paid 45 cents per minute next year and 61 cents per minute in 4 years;
- registered dieticians, who currently earn 47 cents per minute for certain tasks, will be paid 53 cents per minute next year and 70 cents per minute in 4 years; and
- orthoptists, who currently earn 37 cents per minute for certain tasks, will be paid 47 cents per minute next year and 76 cents per minute in 4 years.
“This critical update will enable physician practices to hire and retain nurses, medical assistants and other integral members of the care team as it is phased in,” Ransone said.
Brian Outland, PhD, director of regulatory affairs for ACP, told Healio Primary Care that “clinical labor was at risk of becoming undervalued over time relative to equipment and supplies.”
“ACP was pleased to see that CMS finalized its proposal to update the clinical labor pricing for 2022,” he said.
ACP also said that phasing in these payment increases “will help provide payment stability and maintain beneficiary access to care.”
Critical care services
The final rule enables “longstanding policies” regarding critical care services to be clarified, CMS said.
So long as certain conditions are met, critical care services can be reimbursed on the same day as other evaluation/management visits “by the same practitioner or another practitioner in the same group of the same specialty” and “paid separately in addition to a procedure with a global surgical period,” CMS said.
Outland said that some of the clarifications stem from feedback that ACP provided to CMS during the rule’s comment period.
“ACP was deeply concerned with CMS’ proposed policy in this context, and we are extremely happy to see that CMS listened to the feedback that we gave them,” he said.
He added that “these policies are important because patients who are critically ill or injured require complex care that is often extremely difficult to manage and time consuming.”
“These changes will allow for clinician work to be appropriately paid as a separate service and are a step in the right direction towards adequately recognizing the value of these services,” he said.
‘Significant strides’ in telehealth
CMS said that the final rule allows for counseling, therapy and treatment of substance use disorders and services offered through opioid treatment programs to be conducted via audio-only telephone calls.
In addition, and for the first time outside of the COVID-19 public health emergency, Medicare will reimburse mental health visits that are conducted by rural health clinics and federally qualified health centers through telecommunications technology such as audio-only telephone calls, according to CMS.
“The final rule makes significant strides in expanding access to behavioral health care, especially for traditionally underserved communities,” CMS said.
Ransone said that he was “encouraged” by the telehealth components of the final rule, but additional reform is still needed.
“These services have been a lifeline for many beneficiaries during the pandemic,” he said. “The AAFP looks forward to working with Congress and the administration to ensure ongoing coverage and fair payment of comprehensive primary care services via telehealth, including audio-only visits, after the end of the public health emergency.”
Outland said that ACP was also “happy to see these increased flexibilities .... but we remain disappointed that evaluation/management services outside of mental health services were not included.”
2022 Medicare Physician Fee Schedule represents step toward prioritizing primary care, family medicine. https://www.aafp.org/news/media-center/statements/2022-Medicare-Physician-Fee-Schedule.html. Published Nov. 3, 2021. Accessed Nov. 9, 2021.
AMA statement on Physician Fee Schedule Final Rule. https://www.ama-assn.org/press-center/press-releases/ama-statement-physician-fee-schedule-final-rule. Published Nov. 2, 2021. Accessed Nov. 9, 2021.
AMA. Congress must not take physicians’ Medicare pay to build bridges. https://www.ama-assn.org/practice-management/medicare-medicaid/congress-must-not-take-physicians-medicare-pay-build-bridges. Published July 27, 2021. Accessed Nov. 9, 2021.
CMS. Medicare Program; CY 2022 Payment Policies under the Physician Fee Schedule and Other Changes to Part B Payment Policies; Medicare Shared Savings Program Requirements; Provider Enrollment Regulation Updates; and Provider and Supplier Prepayment and Post-payment Medical Review Requirements. Published Nov. 2, 2021. Accessed Nov. 9, 2021.
CMS. 3 Final Payment Rules. Published Nov. 2, 2021. Accessed Nov. 9, 2021.
CMS. Calendar Year (CY) 2022 Medicare Physician Fee Schedule Final Rule. https://www.cms.gov/newsroom/fact-sheets/calendar-year-cy-2022-medicare-physician-fee-schedule-final-rule. Published Nov. 2, 2021. Accessed Nov. 9, 2021.
Internists say 2022 Medicare Fee Schedule includes positive changes for physicians. https://www.acponline.org/acp-newsroom/internists-say-2022-medicare-fee-schedule-includes-positive-changes-for-physicians. Published Nov. 3, 2021. Accessed Nov. 9, 2021.