On July 13, 2021, CMS released the calendar year (CY) 2022 Medicare Physician Fee Schedule (PFS) Proposed Rule. The rule will be posted in the Federal Register on July 23, 2021.
What you need to know
- The CY2022 proposed conversion factor will be reduced to $33.58, a $1.31 cut from CY2021.
- Peroral endoscopic myotomy (POEM) and colon capsule endoscopy will get new CPT codes and payments.
- Coinsurance requirements for screening colonoscopies that result in removal of polyp(s) will be phased out by Jan. 1, 2030.
- Effective Jan. 1, 2022, physician assistants can bill and be paid directly for their services.
- The Merit-Based Incentive Payment System (MIPS) will be revised and phased-out and will move towards the MIPS Value Pathways (MVPs) system beginning in 2023.
- CMS will remove the Photodocumentation of Cecal Intubation quality measure from claims reporting (QID425); the measure will remain available for registry reporting.
Proposed payment charts for GI
2022 proposed conversion factor and impact to GI
The proposed CY2022 PFS conversion factor is $33.58, a decrease of $1.31 from the CY2021 PFS conversion factor of $34.89. The PFS conversion factor reflects the expiration of the 3.75 percent payment increase provided for CY2021 by the Consolidated Appropriations Act. This congressional intervention averted a significant cut in Medicare physician payment that would have resulted in an almost 10 percent payment cut to GI services on average. Your GI societies will be working to secure congressional action to avert cuts to physician payments next year as physician practices across the country continue to recover from the pandemic.
New CPT codes and values for POEM and colon capsule endoscopy
CMS proposes a valuation of 13.29 physician work relative value units (wRVUs) for POEM and 2.41 wRVUs for colon capsule endoscopy. Our societies thank everyone who received and completed a survey. It would have been impossible to successfully present these codes without accurate data from those of you who perform the procedure. The GI societies appreciate all the work of the physician advisors in shepherding these codes through the CPT Editorial Panel and the RVS Update Committee (RUC).
Implementation of the Removing Barriers to Colorectal Cancer Screening Act
CMS plans to implement changes made last year by Congress to beneficiary cost-sharing obligations when a polyp or other growth is found and removed as part of a screening colonoscopy or screening flexible sigmoidoscopy. Currently, any additional procedure beyond the planned colorectal preventive screening services results in a patient having to pay coinsurance. Beginning Jan. 1, 2022, beneficiary coinsurance will be 20 percent, phasing out to zero by Jan. 1, 2030. Thank you GI society members for all of your advocacy efforts over the years to make this change happen!
Billing for physician assistant (PA) services
CMS is implementing a change in statute to remove the requirement to make payment for PA services only to the employer of a PA effective Jan. 1, 2022. With the removal of this requirement, PAs will be authorized to bill the Medicare program and be paid directly for their services as do nurse practitioners (NPs) and clinical nurse specialists (CNSs) currently. Effective with this amendment, PAs also may reassign their rights to payment for their services, and may choose to incorporate as a group composed solely of practitioners in their specialty and bill the Medicare program, in the same way that NPs and CNSs now may do.
Proposed changes to the Quality Payment Program
CMS proposes to revise and phase-out the Merit-Based Incentive Payment System (MIPS) and move towards the MIPS Value Pathways (MVPs) system beginning in 2023 performance year (PY). CMS is statutorily required to weigh the MIPS Cost and Quality performance categories equally beginning with PY2022. Thus, the PY2022 MIPS performance categories as proposed are:
- Quality: 30%
- Cost: 30%
- Promoting Interoperability: 25% (no change from 2021)
- Improvement Activities: 15% (no change from 2021)
CMS is also required by law beginning in 2022 to set the MIPS performance threshold to either the mean or median of the final scores for all MIPS eligible clinicians for a prior period. CMS is proposing to use the mean final score from the 2017 performance year/2019 MIPS payment year, which would result in:
- The 2022 performance threshold would be set at 75 points.
- An additional performance threshold would be set at 89 points for exceptional performance, which is the 25th percentile of actual 2017 final scores above 75 points.
Photodocumentation of cecal intubation (QID425)
CMS is proposing to remove this measure from claims-based reporting, indicating it has reached the end of its topped out lifecycle. The measure will still be available as a Clinical Quality Measure (CQM) (i.e., reporting via qualified registry and qualified clinical data registry) as benchmarking data continues to show a gap in performance among providers reporting the measure via this collection type. This change could impact small GI practices which choose to report quality measures via claims.
The GI societies are beginning our analysis of the Medicare PFS Proposed Rule and will be submitting comments together.