AMA Releases CMS CY 2022 PFS Final Rule Summary

The American Medical Association (AMA) prepared a summary of the CY 2022 Physician Fee Schedule (PFS) final rule released by the Centers for Medicare & Medicaid Services (CMS) on November 3. CMS also released a fact sheet highlighting the key provisions contained in the final rule. The policies in the rule are scheduled to take effect Jan. 1, 2022, and cover several topics, including the CY 2022 rate setting and Medicare conversion factor, telehealth and other services involving communications technology, and updates to the Quality Payment Program (QPP) through Merit-based Incentive Payment System (MIPS) activities, methodology, and payment adjustments. 

A portion of the AMA's Executive Summary follows:

• The final conversion factor for 2022 is $33.5983, which reflects the expiration of the 3.75% increase for services furnished in 2021, the 0.00% update adjustment factor specified under section 1848(d)(19) of the Act, and a budget neutrality adjustment of -0.10%.
• For the 2022 PFS, the RUC submitted 185 recommendations for individual CPT codes. CMS implemented the recommended work values for 77% of these services and nearly all of the direct practice expense recommendations. 
• CY 2022 will be the final year of transition to the new CMS prices for medical supplies and equipment.
• For 2022, CMS will implement new wage data from the United States Bureau of Labor Statistics and will update clinical labor costs over a four-year transition period.
• CMS will continue to pay for services placed temporarily on the telehealth list through the end of 2023.
• CMS finalized its proposal to delay enforcement of the Appropriate Use Criteria (AUC) program by at least one year until the later of January 1, 2023, or in January after the end of the public health emergency (PHE).
• Despite concerns from the AMA, CMS is ending coverage for audio-only E/M services (CPT codes 99441-99443) at the end of the PHE.
• Beginning Jan. 1, 2022, Physician Assistants (PAs) will be authorized to bill the Medicare program and will be paid directly for their services in the same as nurse practitioners (NPs) and clinical nurse specialists (CNSs).
• CMS finalized revisions to the de minimis policy previously finalized in the CY 2020 PFS final rule which delineates when the -CQ and -CO modifiers apply.

The full AMA summary is available here.