CMS released the 2022 Proposed Physician Fee Schedule yesterday. The 1,747 page document contains numerous, important proposals including:

  • Massive changes to evaluation and management (E/M) services, including:
    • Rules governing split shared and critical care
    • Definitions for “substantive portion”, “distinct time”, “qualifying time”
    • Prolonged services
    • New modifier for split shared
  • Decrease in the conversion factor to $33.55 from $34.89
  • New codes for chronic care management and principal care management
  • Retention of all telehealth approved services until 2023 (no new codes added)
  • Appropriate use criteria (AUC) for advanced diagnostic imaging penalties delayed until 2023
  • DSMT and MNT revisions including removal of the treating physician restriction and updating the GFR eligibility criteria for chronic kidney disease (CKD)
  • Removal of 2 National Coverage Determinations (NCD) for enteral and parenteral nutrition therapy and positron emission tomography (PET) scans 
  • Coverage updates for cardiac and pulmonary rehabilitation
  • Revisions to the physician self-referral rules

We recommend you read the entire Proposed Rule in order to identify all of the changes applicable to your practice.  We will be providing more detailed analysis in the upcoming days.

The Proposed Rule is available here: https://www.cms.gov/medicaremedicare-fee-service-paymentphysicianfeeschedpfs-federal-regulation-notices/cms-1751-p

HBE’s team of coding and compliance experts is available to assist you with external reviews of your documentation, coding and reimbursement as well as providing customized education and training for your staff. We are also available to provide assistance with conducting risk assessments, internal investigations and policy and procedure development.

DISCLAIMER:  This newsletter contains only summary information and highlights; it should be read in conjunction with the full article or document provided as a link.  Any advice or recommendations are general and specific questions should be directed to professional counsel

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