CMS Releases 2022 Medicare Physician Fee Schedule and Quality Payment Program Final Rule

On November 2, 2021, the Centers for Medicare & Medicaid Services (CMS) released its Medicare Physician Fee Schedule and Quality Payment Program (QPP) Final Rule. The rule includes payment and quality provisions that take effect on January 1, 2022.

Payment Provisions

Conversion Factors

The conversion factors decrease as anticipated, but ASA and others will continue our work to get Congressional relief. As was that case for 2021, final resolution may not come until late December. However, the conversion factors as published today are as follows:

*The conversion factors as published reflect the take back of the 3.75% increase Congress approved for the 2021 fee schedule. In addition, physicians and other health care professionals are facing reinstatement of a 2% sequestration cut plus a 4% PAYGO cut that is part of the American Rescue Plan.

Code Level Changes

Anesthesia:  The rule finalizes the base unit values for the six new anesthesia codes. It also finalizes an increase in the base unit value that CMS uses for code 00537.

Pain Medicine: The work Relative Value Units ( RVUs) two new codes for basivertebral lesioning  and for facet joint denervation (codes 64633-64636) are announced within the rule.

Please address questions on the above to Sharon Merrick at [email protected]

Quality Provisions

The 2022 final rule also provides details on how the Merit-based Incentive Payment System (MIPS), MIPS Value Pathways (MVPs), Alternative Payment Models and other features of the QPP will operate during the 2022 performance year and beyond.

ASA is excited that CMS finalized the Anesthesiology MVP for the 2023 reporting year. ASA advocated for the inclusion of an anesthesiology-specific MVP for several years and we believe the MVP will reduce burden for most anesthesiologists and their groups.

In 2022, QPP participants will see some modifications to the program, including:

• The MIPS performance threshold will be set at 75 points with an exceptional performance bonus applied to those individuals and groups scoring over 89 points. Individuals and groups receiving less than 75 points will incur a payment penalty on a linear sliding scale up to 9% in 2024 with those scoring under 18.75 points incurring an automatic -9% adjustment.
• The quality and cost performance categories will be equally weighted at 30% of the total MIPS score. Promoting interoperability and Improvement Activities performance categories will maintain their respective 25% and 15% weights.
• The retirement of MIPS #44: Coronary Artery Bypass Graft (CABG): Preoperative Beta-Blocker in Patients with Isolated CABG Surgery measure from the MIPS program.
• The PSH Care Coordination improvement activity is now a “High” weighted improvement activity. This designation will reduce group burden on reporting improvement activities by half.

Of note, CMS did not finalize its proposal to increase the completeness threshold to 80% in the MIPS Quality performance category in 2023. Instead, CMS will maintain a completeness of 70% for the next two years.

ASA expects to update its Quality Payment Program website in the next few weeks with regulatory information and the Anesthesia Quality Institute expects to publish its 2022 QCDR measures book by mid-December as well. CMS expects to publish the 2022 MIPS measure specifications and other regulatory guidance within the next few weeks on the QPP website.

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

ASA’s physician and staff leadership will carefully review the entire 2,414-page rule and we will post more information in the coming weeks.