ASA Submits Comments on CMS’s Proposed Rule for the CY2022 Medicare Physician Fee Schedule/Quality Payment Program

In comments to the Centers for Medicare & Medicaid Services (CMS), ASA provides strong feedback to CMS on many issues of importance. These include concerns about the CY 2022 Medicare Conversion Factors, the valuation of specific anesthesia and pain medicine services, resource costs for services that use innovative technologies, separate coding and payment for chronic pain management, anesthesia for certain colorectal cancer screens, telehealth, and split billing of critical care services. We provide detailed feedback on Quality Payment Program proposals for 2022, including how the MIPS Value Pathways mechanism will be implemented. We encourage CMS to finalize the “Patient Safety and Support of Positive Experiences with Anesthesia MIPS Value Pathway (MVP)” and agree with their proposal to reduce the reporting burden for those reporting an MVP. ASA also supports CMS in increasing the Perioperative Surgical Home Improvement Activity to a “High-Weighted” activity. We disagree with CMS in their proposals to remove bonus opportunities in MIPS as well as their proposal to increase the reporting rate in future years.

We expect that CMS will issue a final rule and determination on these features of the MPFS and QPP later this year.