CMS Releases Final 2022 Medicare Payment Rules – Key Changes for ATS Members
The Centers for Medicare and Medicaid Services released the final Medicare Physicians Fee Schedule for 2022. The rule established payment, coverage and compliance policy for physician and other Medicare Part B providers. The final rules include a number of important policy changes for ATS members, including:

• Medicare Conversion Factor - The 2022 Medicare conversion factor is $33.59, a cut of $1.30 from the 2021 conversion factor. The cut was largely caused by the expiration of the 2021 3.75 percent payment increase – driven by the COVID-19 response legislation and budget neutrality adjusts caused by change in RVUs.

• Concurrent Critical Care - When medically necessary, critical care services can be furnished concurrently to the same patient on the same day by more than one practitioner representing more than one specialty.
• Critical Care and E/M services - In limited circumstances, CMS will allow critical care and E/M services billed on the same day.
• Critical Care and Surgical Bundle – CMS will continue to allow separate critical care services during a 10-day or 90-day surgical global period.
• Split/Shared Billing – CMS provided additional guidance on the appropriate use of split/shared billing.
• Pulmonary Rehabilitation New CPT Codes - The final rule includes the new CPT codes for office based pulmonary rehabilitation (94625 & 94626) and retired the existing G-code for pulmonary rehabilitation (G0424).
• Pulmonary Rehabilitation and Long COVID – CMS finalized coverage for outpatient pulmonary rehabilitation services, paid under Medicare Part B, to beneficiaries who have had confirmed or suspected COVID-19 and experience persistent symptoms that include respiratory dysfunction for at least four weeks.

In related news, CMS also released the 2022 final payment rule for Hospital Outpatient Prospective Payment Systems, which includes coverage as well as the reimbursement policy for outpatient pulmonary rehabilitation. In the final rule, CMS rejected the ATS request to move the Ambulatory Payment Classification (APC) for pulmonary rehabilitation to a higher payment rate. CMS instead kept the new pulmonary rehabilitation CPT codes (94625 & 94626) in the current APC 5733 with a reimbursement rate of $57.12.

For more detailed information and discussion of the 2022 Medicare Physician Fee Schedule and how it may impact your practice, please look for the forthcoming edition of the ATS Coding and Billing Quarterly, expected shortly.