ACR Responds to 2022 Medicare Physician Fee Schedule Proposed Rule

ATLANTA—In comments submitted to the Centers for Medicare and Medicaid Services (CMS), the American College of Rheumatology (ACR) shared its perspective on the CY 2022 Medicare Physician Fee Schedule and Quality Payment Program proposed rule.

“We are especially appreciative of CMS’ continued recognition of the value of complex care provided by rheumatologists and other cognitive care specialists by continuing to operationalize the Evaluation and Management (E/M) coding changes that were set in motion over the last few years. As our nation’s healthcare system continues to navigate the challenges of a global pandemic, we also appreciate the policies and flexibilities set forth by CMS to help alleviate these challenges while we all work to provide quality care for our patients,” said David Karp, MD, PhD, president of the ACR. “In light of ongoing volatility and unknowns in the healthcare system, we would also like to share our concerns with some other aspects of the proposed rule – especially the proposed decrease in the conversion factor, CMS’ proposed implementation of the rheumatology MIPS Value Pathway and a new proposal for EHR interoperability and digital quality measures.”

The ACR’s specific comments and concerns are summarized below:

Evaluation and Management Services

The ACR appreciates CMS’ ongoing commitment to implementing recent changes to E/M codes that more appropriately reflect the value of cognitive specialists and urges the agency to continue monitoring how the updated codes are operationalized. The ACR also appreciates the proposed rule’s revisions to the long-standing policy on billing for split (or shared) visits but wants to ensure that these changes don’t become burdensome for providers, especially as it relates to time tracking for the “substantive performance” of the provider, as this can introduce the potential for billing errors.

Telehealth Flexibilities

CMS has proposed extending several of the telehealth flexibilities that were implemented at the start of the public health emergency through the end of 2023.  The ACR appreciates this additional flexibility and recommends that the direct supervision waiver allowing a supervising physician to serve patients using real-time, interactive audio-video technology be made permanent. This would immediately provide timely access to cognitive services for Medicare beneficiaries and relieve an undue burden to an aging population.

The ACR also supports CMS’ proposal to permanently adopt a code (G2252) for an extended virtual check-in. This allows a provider to briefly check in with an established patient using any form of synchronous communication technology, including audio-only, and will be especially beneficial to patients in rural areas.

Conversion Factor Reduction, Physician Work and Practice Expense (PE) Relative Value Changes

The ACR shares the concerns raised by many specialty provider groups about CMS’ proposal to reduce the conversion factor by 3.75% in 2022 and urges the agency to maintain the current rate at least through 2023. The proposed reduction comes at a time when physician practices and hospitals are facing unprecedented uncertainty about their futures amid the COVID-19 pandemic. Implementing reductions now would have a damaging impact on an already strained system.