On July 13, 2021, the Centers for Medicare & Medicaid Services (CMS) released its proposed rule for the 2022 Medicare Physician Fee Schedule (PFS) and updates to the Quality Payment Program (QPP). The Association for Clinical Oncology (ASCO) is still analyzing the full proposal, but based on a preliminary analysis, key provisions for the cancer care community include:
CMS has proposed a Calendar Year (CY) 2022 Physician Conversion Factor of $33.5848. This represents a 3.75% reduction from the 2021 Physician Conversion Factor of $34.8931. This reduction is largely a result of the expiration of the 3.75% increase for services furnished in CY 2021, as provided by the Consolidated Appropriations Act of 2021.
CMS estimates a negative 2% overall impact for the hematology/oncology specialty and a negative 5% overall impact for the radiation oncology specialty in 2022. Actual impact on individual clinicians, however, will vary based on geographic location and mix of Medicare services billed.
CMS is proposing to allow certain services added to the Medicare telehealth list to remain there until December 31, 2023—with ongoing evaluation of whether the services should be permanently added to the telehealth list after the COVID-19 public health emergency (PHE) is lifted.
The proposal would limit the use of audio-only interactive telecommunications systems to mental health services furnished by practitioners who have the capability of furnishing two-way audio/video communications, but where the beneficiary is not capable of, or does not consent to, the use of two-way audio/video technology.
Colorectal cancer screening
Beginning in 2022, the coinsurance required of Medicare beneficiaries for planned colorectal cancer screening tests that result in additional procedures furnished in the same clinical encounter will be gradually reduced from 20% on January 1, 2022 to zero percent on January 1, 2030.
CMS is proposing to implement a recent statutory change that authorizes Medicare to make direct payments to Physician Assistants (PAs) for professional services they furnish under Part B. Beginning January 1, 2022, for the first time, physician assistants would be able to bill Medicare directly.
For 2022, the Merit-based Incentive Payment System (MIPS) performance threshold would be set at 75 points. The additional performance threshold would be set at 89 points. CY 2022 performance category weights would be set as follows: 30% for the quality performance category, 30% for the cost performance category, 15% for the improvement activities performance category, and 25% for the promoting interoperability performance category.
Qualifying APM participants (QPs) for the year would receive a 5% lump sum incentive payment during the corresponding payment year through CY 2024 or a differential payment update under the PFS for payment years beginning in 2026.
As proposed in earlier rules, CMS is moving forward with MIPS Value Pathways (MVPs). CMS is proposing to begin transitioning to MVPs in the 2023 performance year. Subgroup reporting would be voluntary for 2023 and 2024. Beginning in the 2025 performance year, multispecialty groups would be required to form subgroups in order to report under MVPs. CMS is also requesting public comment on sunsetting traditional MIPS after 2027.
The seven MVP options described in the rule do not include an oncology MVP.
The proposal lists CMS’ Oncology Care Model (two-sided risk) and Radiation Oncology Model as Advanced APMs for 2022. The Most-Favored Nation Model, previously proposed by the Center for Medicare and Medicaid Innovation (CMMI) as a model for 2022, is not referenced.
The rule also contains two requests for information (RFIs): 1) Advancing to Digital Quality Measurement and the Use of Fast Healthcare Interoperability Resources (FHIR) in Physician Quality Programs, and 2) Closing the Health Equity Gap in CMS Clinician Quality Programs.
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