July 20, 2021

Last week, CMS released the CY 2022 Medicare Physician Fee Schedule (MPFS) Proposed Rule. As proposed, the CY 2022 Conversion factor would drop from $34.891 to $33.5848 due to the expiration of the +3.75-percent one-year update Congress provided at the end of last year in the Consolidated Appropriations Act, plus an additional -0.14-percent budget neutrality adjustment as required by statute. APMA is working with its partners in Congress and other medical specialty societies to push for congressional intervention to delay or cancel further cuts to Medicare reimbursement.

While APMA continues to review the proposed rule, some proposals of note include:

• Maintaining certain telehealth services that have been added to the telehealth list during the public health emergency (PHE) through end of CY 2023. However, CMS proposes to limit payment of audio-only services to mental and behavioral services following the end of the PHE.
• As APMA requested, CMS has proposed to delay the penalty phase of AUC implementation until the later of January 1, 2023, or January 1 in the year that follows the declared end of the PHE. APMA has long advocated for Congress to end or modify the AUC program.
• CMS proposes to allow exceptions for prescribers who issue 100 or fewer Part D controlled substance prescriptions in a calendar year to the already-existing requirement that ePrescribing be used for controlled substances.
• Convert CPT 28001, 28002, and 28003 to 0-day Globals and reduce values accordingly.
  
• As required by statute, change the MIPS performance threshold to 75 points and change 2022 MIPS category weights to:
  • Quality—30 percent;
  • Promoting Interoperability—25 percent;
  • Improvement Activities—15 percent; and
  • Cost—30 percent.
• CMS also proposes automatic reweighting of the Promoting Interoperability category for small practices.

APMA will prepare and submit comments by September 13.

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