CMS Releases 2022 Physician Fee Schedule and Quality Payment Program Proposed Rule

The Centers for Medicare and Medicaid Services (CMS) has released a 1,747 page rule with its proposed actions for CY 2022.

Fee Schedule Provisions:

Conversion factors (CF) are proposed to decrease due to two factors:

• Re-capture of the funds Congress provided for 2021 via the Consolidated Appropriations Act in late December. The starting point for 2022 conversion factor calculations is what the CF would have been without that Congressional action.
• A statutorily required budget neutrality adjustment.

Anesthesia Code Updates

The descriptor for code 00537 is unchanged but the code has been revalued and CMS is proposing to increase the base unit value it assigns to this service.

 Two anesthesia codes will be deleted and replaced with six new codes that more specifically describe the care.

Pain Medicine Code Updates

The codes that describe facet joint ablation underwent review and revaluation as having been identified as potentially misvalued services. The primary codes will see a decrease in work relative value units (RVU) while the associated add-on codes will hold their current value.

Overall Impact to ASA Members:

The rule includes an estimated specialty specific impact should all provisions be finalized as proposed. Anesthesiology, Interventional Pain Mgmt and Nurse Anesthetists/Anesthesiologist Assistants are slated for a positive 1% impact.

For questions on the fee schedule provisions, please email [email protected].

Quality Payment Program Provisions:

CMS also released its 2022 Quality Payment Program (QPP) Proposed Rule. The proposed rule provides details on how CMS intends for eligible clinicians and groups to participate in the Merit-based Incentive Payment System (MIPS), Alternative Payment Models and other features of the QPP during the 2022 performance year.

For 2022,

• CMS is proposing to establish the performance threshold using the mean score from the 2019 MIPS payment, which would result in a performance threshold of 75 points. Scoring 75 points out of 100 total points would allow groups and individuals to avoid a negative payment adjustment. Earning 89 points will result in an exceptional performance bonus.
• By law, the quality performance category will be weighted at 30% and the cost performance category will be weighted by 30%. Promoting interoperability and Improvement Activities performance categories will maintain their respective 25% and 15% weights.
• CMS is maintaining most of the Anesthesiology Specialty Measure set, retiring and removing QID044 (Coronary Artery Bypass Graft (CABG): Preoperative BetaBlocker in Patients with Isolated CABG Surgery) from the program.
• CMS has proposed an end to “traditional” MIPS after calendar year 2027 with a mandatory move to MIPS Value Pathway (MVP) reporting at the beginning of calendar year 2028.

ASA is pleased that CMS has proposed an anesthesiology MVP for 2023. CMS believes that MVPs will alleviate some of the reporting burden that anesthesiologists and other physicians encounter and at the same time, improve the care that is delivered to beneficiaries. CMS describes many of these provisions and how MVPs would be scored in the rule. The Anesthesiology MVP is one of just seven proposed for 2023.

For more information on the Quality Payment Program, please contact the ASA Department of Quality and Regulatory Affairs (QRA) at [email protected].

ASA leaders and staff will review the rule and submit comments by the Sept 13, 2021 deadline. Finalized provisions will become effective January 1, 2022.

For More Information:

• Proposed rule
• Medicare PFS Proposed Rule fact sheet
• QPP fact sheet