The CY 2022 Medicare Physician Fee Schedule Final Rule was released on November 2, 2021, and with it came some important changes including updates to payment rates for 2022, expanding the use of telehealth for mental health, and allowing PAs to bill Medicare directly.
Conversion Factor Decrease
A significant change was made to the conversion factor which was decreased to $33.59. This is $1.30 lower than the CY 2021 conversion factor. This decrease accounts for statutory changes to relative value units (RVUs) and the expiration of the 3.75% temporary CY 2021 payment increase that was approved by Congress through pandemic-related legislation.
As telehealth becomes more important in providing healthcare, the rule also eliminates geographic barriers when it comes to utilizing telehealth for behavioral healthcare. The rule allows patients to access telehealth services from their homes versus a qualifying healthcare site for diagnosis, evaluation, and treatment of mental health disorders.
CMS also finalized an extension for services added to the telehealth list originally due to the COVID-19 pandemic. It includes the extension of some cardiac and intensive cardiac rehabilitation codes on the telehealth list through the end of CY 2023.
Additional services added to the Medicare telehealth list are to remain through Dec. 31, 2023, allowing time to evaluate whether the services should be added permanently following the cancelation of the COVID-19 public health emergency (PHE).
Through this final rule, CMS will support an additional priority from the COVID-19: administration of vaccinations. The final rule addresses a higher Medicare reimbursement rate for the administration of certain vaccines. The rule outlines that Medicare will pay $30 per dose for administering the vaccinations for influenza, pneumococcal, and hepatitis B virus, nearly doubling the amount paid for these vaccines and will continue to pay $40 per dose for the administration of the COVID-19 vaccines.
Direct Billing for PAs
Starting January 1, 2022, physician assistants (PAs) will be able to bill Medicare directly for their professional services along with being able to reassign payment. This only applies to Medicare and does not affect Medicaid reimbursement policies or commercial payers. This will benefit those PAs who want to work as independent contractors or want to own a practice or medical corporation.
One thing to remember is that Medicare regulations defer to state law, so if the state law or regulations prohibit a PA from receiving direct payments then this doesn’t apply unless the state has also updated its regulation.
Split or Shared Evaluation and Management Visits
CMS finalized an update to the definition of split or shared E/M visits provided in a facility setting with a physician and a non-physician practitioner in the same group. The determination is that the visit is to be billed by whichever person provides the substantive portion of the visit. The substantive portion of the visit is defined as more than half of the time spent with the patient whether it is gathering history, physical exam, or medical decision making.
Other requirements that have to be met are:
- Physician/NPP must work for the same group;
- Physician/NPP must see the patent on the same calendar day;
- Services must be performed in a hospital, facility, or hospital outpatient office;
- Must have a claims modifier to indicate a split, or shared, service for monitoring purposes by CMS;
- Documentation must identify the physician and PA or nonphysician provider who performed the visit. And the individual who provides the substantive portion (spends the most time) of the visit must sign and date the medical record as well as bill for the visit.
Statement from CMS
“The COVID-19 pandemic has highlighted the gaps in our current health care system and the need for new solutions to bring treatments to patients, wherever they are,” CMS Administrator Chiquita Brooks-LaSure said in an announcement of the new rule. “This is especially true for people who need behavioral health services, and the improvements we are enacting will give people greater access to telehealth and other care delivery options.”
The 2022 PFS Final Rule addresses a wide range of other material topics, besides those listed above including clinical labor practice expense values, changes to the Stark Law Regulations, Medicare diabetes prevention program expanded model, Quality Payment Program Provisions to name a few.
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