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This week, the Centers for Medicare and Medicaid Services (CMS) published the 2022 Physician Fee Schedule (PFS) final rules that will govern payments starting on January 1^st.  According to CMS, the final rule will promote greater use of telehealth and other telecommunications technologies for providing behavioral health care services, encourage growth in the diabetes prevention program, and boost payment rates for vaccine administration.  Here are some highlights of changes for 2022:

• Bad news for Medicare’s physician payments, which are based on the relative resources used to furnish a service.  These relative units are converted into a dollar amount by applying a conversion factor, which will be $1.30 lower in 2022 than in 2021 due to budget neutrality provisions and the expiration of a 3.75% temporary payment increase.  The AMA translates this into a 4% reduction in physician payments next year. 

• Greater definition was given to split or shared evaluation and management (E/M) visits.  These occur when a physician and non-physician practitioner in the same group perform parts of the same visit.  The visit is billed under the provider who rendered the substantive portion of the services, which will be defined in 2022 as more than half of the total time spent, or the history, physical exam and medical decision-making combined.

• The COVID-19 pandemic certainly highlighted a critical need for behavioral health services; their delivery via telehealth (audio only) have greatly enhanced access and benefited millions.  At least for next year, patients will be able to avail themselves of telehealth services for diagnosis, evaluation, and treatment of mental health disorders, which includes treatment of substance use disorders and services provided through Opioid Treatment Programs.

• CMS is also expanding its Medicare Diabetes Prevention Program (MDPP) which has a goal of preventing pre-diabetics from developing type 2 diabetes through training in dietary change, increased physical activity, and weight loss strategies.  New MDPP suppliers who enroll after January 1 will face a waived enrollment fee, less administrative burdens and costs, and larger payments for participants who reach milestones for attendance.

• Medical Nutrition Therapy (MNT) providers will also be able to reach more patients needing nutritional diagnostic, therapeutic and counseling services.  The final rule removed some restrictions in who could refer for these services.  Beginning in January, any M.D. or D.O. – instead of only the “treating” physician – can refer Medicare beneficiaries for MNT.  Finally, the upper limit for patients with chronic kidney disease who qualify for these services was expanded to a GFR of 59 mL/min/1.72m², instead of 50.  This means that additional patients with less severe kidney damage may receive MNT services, which could delay progression of their disease.

• 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, and also continue the additional payment of $35.50 for vax administration in the home. In addition, CMS will also continue to facilitate vaccinations for common diseases such as influenza, pneumonia, and hepatitis B. This final rule will nearly double Medicare Part B payment rates for influenza, pneumococcal, and hepatitis B vaccine administration from roughly $17 to $30.  Monoclonal antibody administration will continue to generate a $450 payment for admin in a health care setting and $750 for this therapy’s administration in the home.

• The mandate for electronic prescribing of controlled substances will have a few exceptions in 2022. Among the waivers:  if the prescriber issues 100 or fewer controlled substance prescriptions per year; of the prescriber is in an emergency or disaster areas as declared by the government; or is subject to circumstances beyond his/her control, such as technological failure or cybersecurity attack.   The start date for compliance actions has been rolled back to January 1, 2023.

• Finally, CMS is implementing a recent statutory change that authorizes Medicare to make direct payments to Physician Assistants (PAs) for the professional services they furnish under Part B. For the first time, beginning January 1, 2022, PAs will be able to bill Medicare directly. As a result, more individuals with Medicare will have access to these services as PAs will now have the same opportunity as certain other practitioners to bill Medicare for professional services.

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