CMS Publishes Proposed Physician Fee Schedule and QPP MIPS Rules 2022

On July 13, the Centers for Medicare and Medicaid Services (CMS) published the proposed regulation for the 2022 Medicare Physician Fee Schedule (PFS) and Quality Payment Program (QPP). This rule also expands the use of telehealth, clarifies assessment and management (E / M) policies, proposes policies for the 2022 performance year of the quality payment program, and contains many other provisions. It also contains updates to payment rates for doctors and other health professionals.

The propos rule will receive comments from the AAMC, which must be submit to CMS by September 13th.

The following are some of the primary claims of the rule:

The Physician Fee Schedule’s salient features are:

The factor of conversion: decreases the conversion factor by $1.31, from $ 34.89 for the 2021 calendar year (CA) to $ 33.58 for the 2022 CA. This is in part because of the Consolidated Appropriations Act’s 2021 provision for the pay rise of 3.75% to expire.

Improve E/M policies: explains and improve the rules governing split (or shared) ER visits, intensive care, and services rendered by teaching doctors that involve residents.

Split or joint visits: defines split (or shared) E/M visits as visits made to a facility by a doctor and a non-medical provider who are both members of the same organization, and it specifies that the practitioner who makes up the lion’s part of the visit will be the one who bills for it.

Teaching about medical time: explains that when calculating the E/M visit level, the time the teaching physician was present may be taken into account. The degree of visit would only be determined by medical decision-making under the primary care exception in particular.

Prohibited substance prescriptions made electronically: specifies exceptions to the electronic prescribing rule for restricted medications and suggests delaying the beginning of compliance measures until January 1, 2023.

Program for Appropriate Use Criteria (AUC): Instead of January 1, 2022, the AUC program payment penalty would begin on January 1, 2023, or the January 1 that follows the announced end of the public health emergency (PHE), whichever is later. The deadline was extend to account for the PHE’s effects on beneficiaries and providers. For accountable care organizations (ACOs) reporting electronic clinical quality measurement and merit-based incentive payment system (MIPS) all payor quality indicators under the paradigm of alternative payment Performance Pathway, the Medicare Shared Savings Program suggests a longer transition period. would give an additional two years, or until the performance year 2023, for data collecting using the CMS web interface.

Telehealth: Allow some of the new telehealth services add to Medicare’s list to stay there until the end of December 31, 2023, so data can be gathere to decide if they should be add to the list permanently at the continuation of COVID-19 PHE.

Featured aspects of the quality payment scheme are as follows:

MIPS Value Path (MVP): The MVPs will begin to take effect in 2023, initially offering seven different choices.

MIPS Sunsets: After the performance and data submission periods conclude in 2027, the Centers for Medicare and Medicaid Services (CMS) will seek feedback on its intention of discontinuing the standard MIPS program.
Sub-groups: Provides the option of reporting performance information on a voluntary subgroup level in order to make it possible to provide performance information at a more granular level. At first, only physicians who reported their data through MVPs or the APM performance route would be eligible to participate in subgroup reporting.

CMS online interface: Shared Savings ACOs can continue to provide quality metrics via the CMS web interface for the performance years of 2022 and 2023. In 2022, it’s possible that some other ACOs and group firms will keep using the Web Interface.
The importance of the following performance categories: The following weightings have determine the performance categories that will be use for the performance year 2022/2024 payment year: 30% for quality, 30% for cost, 15% for improvement initiatives, and 25% for fostering interoperability.

Make changes to the reporting requirements in order to promote interoperability and increase the level of interoperability.
In the category of cost performance: The cost category would be expand to include a total of five additional episode cost measures.