Proposed Medicare Physician Fee Schedule, QPP Released for 2022

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ACP is pleased with proposed changes to telehealth and health equity, continues to advocate against scheduled payment cuts

August 13, 2021 (ACP) -- Federal officials have released the proposed 2022 Medicare Physician Fee Schedule and Quality Payment Program rules, and the American College of Physicians is closely examining them prior to providing comments.

Although ACP will advocate for some changes -- in particular for proper funding for next year -- it is pleased by provisions that provide badly needed support for the continued reimbursement of vital telehealth services. “The stability of knowing those services will continue is important for the physicians who provide them,” Dr. George M. Abraham, president of ACP, said in a press release. “This also better allows the Centers for Medicare & Medicaid Services (CMS) to study the services and will inform future policies on telehealth to make sure they work for patients and physicians.”

The proposed 2022 Fee Schedule is a landmark for physicians because it represents an opportunity to continue pandemic-era adjustments. CMS agrees and wants to keep reimbursement policies in place for another two years -- through 2023 -- for telehealth services implemented at the start of the public health emergency.

“This proposal is consistent with ACP's advocacy that CMS maintain Medicare coverage and payment for the many services that were temporarily added during the public health emergency,” said Brian Outland, ACP director of regulatory affairs. “ACP is encouraged by this extension, as well as the agency's commitment to evaluate whether these changes should be made permanent.”

The proposed Fee Schedule would also permanently expand coverage for audio-only mental health services to increase access to vulnerable populations that would otherwise go without care. “CMS has found that during the public health emergency, one of the most commonly performed telehealth services has been audio-only evaluation and management (E/M) visits, with most beneficiaries receiving mental health services during those visits,” Outland said. “Given the mental health professional shortage and areas in which beneficiaries have limited broadband access due to geographic area or socioeconomic challenges, CMS believes beneficiaries may have come to rely on these audio-only mental health care services. A sudden discontinuation could have a negative impact on access to care.”

ACP enthusiastically supports reimbursement for audio-only services. “However, we believe that because audio-only telehealth is an important component tool for physicians to improve health equity and patient access, it should not be limited to only patients seeking behavioral health services,” Abraham said. “We are asking CMS to broaden the flexibility and continue to allow other E/M services to be provided using audio-only communication.”

On another front, a provision in the Fee Schedule calls for federal officials to begin collecting additional data on health equity issues to analyze disparities that occur across programs. “Access to health equity data may enable a more comprehensive assessment of health equity and support initiatives to close the equity gap,” Abraham said.

There are other positive aspects of the proposed Fee Schedule. “CMS is proposing to postpone the punitive phase of the Appropriate Use Criteria (AUC) program until Jan. 1, 2023, or the Jan. 1 that follows the end of the public health emergency,” Outland said. “The AUC program was originally going to begin at the start of 2022 and penalize clinicians who ordered advanced imaging without consulting a qualified Clinical Decision Support Mechanism.”

According to Outland, ACP is pleased by this move. “The College believes this additional time will enable clinicians and hospitals to maintain their ongoing response to the COVID-19 pandemic, while also allowing essential education and operations testing of the AUC program to occur,” he said.

In regard to the QPP, CMS is proposing seven Merit-based Incentive Payment System (MIPS) Value Pathways (MVPs): Rheumatology, Stroke Care and Prevention, Heart Disease, Chronic Disease Management, Emergency Medicine, Lower Extremity Joint Repair and Anesthesia. “The one most applicable to internists, Optimizing Chronic Disease Management, begins in payment year 2023,” Outland said. “We appreciate CMS's ongoing efforts to incorporate stakeholder input into the design and implementation of MVPs, which we agree is integral to its success.”

However, ACP is “not convinced MVPs go far enough to address the underlying issues or distinguish themselves in a meaningful way from traditional MIPs,” he said. “To do so, CMS must: 1) create more synergy between the performance categories and reduce the overall number of metrics; 2) revamp the Promoting Interoperability Category; and 3) improve the accuracy of cost measurement. Additionally, ACP cannot support the inclusion of any measures that ACP's Performance Measurement Committee has rated as invalid.”

The deadline for comments about the proposed Fee Schedule and QPP is Sept. 13. ACP will respond by then.

Looking forward, ACP is concerned about funding for Medicare physician payments. Proposed cuts are the result of a 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, the cuts will go into effect on Jan 1, 2022.

“We have seen demonstrated over the past year and [a] half why it is critical for Americans to have access to necessary health care. 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,” Abraham said. “While CMS does not have the authority on their own to correct this, we ask them to support efforts to fix the problem through Congress. It is critically important for the administration and Congress to work together to prevent these cuts and ensure stability for patients and their physicians.”

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