Internists Say 2022 Medicare Fee Schedule Includes Positive Changes for Physicians

Appreciates CMS Response to ACP Concerns on Proposed Rule

WASHINGTON, D.C. November 3, 2021 –The American College of Physicians (ACP) says new Medicare rules make key positive changes for physicians; however, areas of concern remain. Changes were made to make it easier to use the codes for providing critical care services to patients in line with recommendations previously made by ACP.  These changes, which were included in the final 2022 Medicare Physician Fee Schedule and Quality Payment Program rule that was released by the Centers for Medicare and Medicaid Services (CMS) yesterday, are a step in the right direction.

In comments reacting to the proposed rule that was released earlier this year, ACP expressed concern about a proposal that would have no longer allowed physicians to report any evaluation and management (E/M) services that were provided to a patient the same day as a critical care visit.  In the same comments, ACP also expressed disagreement with a proposal that would have prevented reimbursement for a critical care visit that occurs while a patient is in a global surgical period. CMS did not include either of these proposals in their final rule.

“ACP is extremely happy to see that CMS listened to the feedback that we gave them on the proposed rule,“ said George M. Abraham, MD, MPH, MACP, FIDSA, president, ACP. “Patients who are critically ill or injured require complex care that is often extremely difficult to manage and time consuming. The changes that were made in the final Physician Fee Schedule for next year, are a step toward better recognizing the value of these services.”

ACP noted several other positive provisions in the final Fee Schedule rule. CMS will allow more time to phase in changes in practice expenses for clinical labor pricing.  Allowing a four-year transition period will help provide payment stability and maintain beneficiary access to care. The Fee Schedule also extended the time that some additional services, which were added on a temporary basis during the COVID-19 Public Health Emergency (PHE), are going to be included in the allowed telehealth services list for Medicare.  ACP supports this extension since they allow for additional time for stakeholders and CMS to gather data supporting the potential permanent addition of these services and would sustain the continuity of increased access to telehealth services by reducing the uncertainty regarding timing relative to the end of the public health emergency.

ACP was glad to see that increased flexibilities for telehealth and coverage for audio-only technology to provide telehealth for mental and behavioral health services will move forward. However, we are disappointed that E/M services were not included. ACP had recommended that CMS should broaden audio-only telehealth beyond mental and behavioral health services.

ACP is also encouraged to see that under the Quality Payment Program the MIPS Value Pathway options for 2023 include four different pathways that are relevant to internal medicine specialists. One of the included pathways, Optimizing Chronic Disease Management, appears similar to a pathway that ACP previously submitted to CMS for their consideration.

Finally, ACP remains extremely concerned about the across-the-board cuts to physician payments that will go into effect at the beginning of 2022. The proposed cuts are the result of a statutorily-required reduction that is necessary to keep Medicare payments budget neutral. At the end of 2020, Congress stepped in to pass a one-year fix that prevented cuts that were due to take effect in 2021. Without additional action by Congress the cuts will go into effect on Jan 1, 2022.

“We are once again facing a potential drastic cut in physician payments at the end of the year,” concluded Dr. Abraham.  “It is imperative that Congress step in to prevent the cuts and ensure stability while our health care system is still in the midst of the COVID-19 pandemic. The impact to physician practices will be even greater when you couple these cuts with the huge impact that the pandemic has had on internal medicine specialists and other frontline physicians.  We need to ensure that practices across the country are able to continue to operate and provide frontline care that improves health equity and patient access in their communities.”


About the American College of Physicians

The American College of Physicians is the largest medical specialty organization in the United States with members in more than 145 countries worldwide. ACP membership includes 161,000 internal medicine physicians (internists), related subspecialists, and medical students. Internal medicine physicians are specialists who apply scientific knowledge and clinical expertise to the diagnosis, treatment, and compassionate care of adults across the spectrum from health to complex illness. Follow ACP on Twitter, Facebook, and Instagram.

Contact: Jacquelyn Blaser, (202) 261-4572,