September 13, 2021

APMA submitted comments to the CMS CY 2022 Medicare Physician Fee Schedule Proposed Rule on September 13. The comments included requesting that CMS:

• maintain flexibilities for services offered through telehealth through the public health emergency (PHE) and allow for a period of transition;
• permit physicians to perform and be paid for audio-only telephone evaluation and management services (CPT 99441-99443) beyond the PHE;
• work with Congress to use its regulatory authority to expand physician supervision of physician assistants to include supervision by podiatric physicians, if permitted by state law;
• take a measured approach to implementing MIPS Value Pathways; and
• review the RUC recommendation for CPT 28002 (treatment of foot infection) and revise its work RVUs based on RUC’s recommendations.

APMA supported several of CMS’ proposals, including:

• exempting prescribers who prescribe 100 or fewer Part D controlled substance prescriptions per year from the Electronic Prescription of Controlled Substances requirement;
• delaying implementation of the Appropriate Use Criteria (AUC) for Advanced Diagnostic Imaging requirement. APMA also urged CMS work with Congress to repeal the program altogether; and
• automatic reweighting of the MIPS Promoting Interoperability Performance Category for Small Practices.

APMA expects the final rule to be released later this fall.

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