The Centers of Medicare and Medicaid (CMS) released the Proposed Rule on the Physician Fee Schedule (PFS) for the calendar year (CY) 2022. Here are a few highlights that staff will be reading and drafting comments on in the coming weeks.
Conversion Factor
Conversion Factor for CY 2022 will be 33.58. The CCA (“Consolidate Appropriations Act”) approved a 3.75 percent payment increase for 2021 which will expire at the end of the year. As a result of this anticipated 3.75 decrease for 2022, there will also be the usual budget neutrality adjustment which will be a decrease of $1.31. This brings the conversion factor to $33.58 for 2022. It is estimated that the whole of Cardiology will have a combined impact of -2%. This will mean that the conversion factor will affect practices in different ways. Staff will be looking this over to provide more information.
Practice Expense
CMS is seeking comments on the practice expense for new CPT codes. CMS agreed with RUC recommendations for new CPT codes for Percutaneous Cerebral Embolic Protection and Exclusion of Left Atrial Appendage that go into effect on January 1, 2022. CMS recommended values for Endovascular Repair of Aortic Coarctation and Cardiac Catheterizations for Congenital Defect CPT codes that are lower than the RUC recommended values. Staff will be reviewing the logic and drafting comments on these values.
NCD
CMS is soliciting comments on the removal of the NCD for Myocardial PET. When the NCD is removed then payment is not automatic. The decision of payment is left to each local Medicare Administrator Contractor.
Cardiology Rehabilitation and E/M Telehealth Services
CMS is seeking comments on what telehealth services should be extended after the end of 2021 (i.e., presumably the end of the public health emergency). SCAI will need to seek input from our members on these services to see if we want to extend them after the year-end for 2021. We may also want to comment on Inpatient, Observation Care, Office/Outpatient services, Critical Care Services, and the G codes for Cardiac Rehabilitation.
FFRCT
CMS is seeking comment on whether other codes would provide a more appropriate crosswalk in terms of resource costs (i.e., a code of similar time and intensity). CMS is also more broadly soliciting public comment to help us better understand the resource costs for services involving the use of innovative technologies, including but not limited to software algorithms and AI.
Quality Programs
Staff will be reviewing quality programs, such as MIPS, ACO, and AUC. CMS is going to provide clarifications and proposals around the scope of the AUC program pertaining to updates or modifications to orders and CMS is proposing a flexible effective date for AUC program claims processing edits and payment penalty phase to being the later of January 1, 2023, or the January 1 of the year after the year in which the PHE for COVID-19 ends.
Additional analysis and commentary will be provided soon. If you have questions, please contact Debra Mariani, Director, Regulatory Affairs at [email protected].