HomeWashington Letter2021 ▶ CLINICAL PRACTICE

Medicare Releases Proposed Medicare Physician Payment Rule
This month, CMS released the proposed Medicare Physician Fee Schedule for calendar year 2022. The proposed rule covers a wide range of policy for physician and other Medicare Part B provider payment and regulations under the Medicare program including:


Conversion Factor – CMS has proposed a conversion factor of $33.58 a decrease of $1.31 from 2021. The conversation factor reflects the expiration of the 3.75 percent increase legislated by Congress for 2021. The ATS and the rest of the physician community are working with Congress to prevent a cut in Medicare reimbursement during the continuing COVID-19 pandemic.


COVID Pulmonary Rehabilitation Benefit – CMS is proposing to expand coverage of pulmonary rehabilitation for all Medicare beneficiaries with a COVID-19 hospitalization. The pulmonary rehabilitation for COVID-19 patients would extend for at least four-weeks post-discharge.


E/M Split/Shared Billing – CMS is proposing changes on its coverage policy for split/sharing billing of E/M services.


Critical Care - CMS is proposing several changes to coverage of physician critical care services (CPT 99291 and 99292), including allowing for critical care services to be provided concurrently to the same patient on the same day by more than one practitioner from different specialties.


Teaching Physician rule – CMS is also making proposed changes to Medicare physician payment policies.


Telemedicine Services – CMS is seeking input on continuing its telemedicine policy it has issued during the COVID-19 Public Health Emergency declaration.


Vaccine Administration – CMS has proposed a $35 fee for vaccine administration to vulnerable Medicare beneficiaries. As the market for COVID-19 monoclonal antibody products matures, CMS is seeking input on whether products should be covered as other physician administered drugs and biologics.


In related news, CMS has also released the proposed rule for Medicare Hospital Outpatient Prospective Payment System. CMS is seeking public comment on the degree to which providers relied on the flexibility to allow the presence of the physician to include virtual presence for purposes of the direct supervision requirement, for pulmonary rehabilitation, cardiac rehabilitation, and intensive cardiac rehabilitation services. Virtual presence is achieved through audio/video real-time communications technology when use of such technology is indicated to reduce exposure risks for the beneficiary or practitioner. This flexibility is scheduled expire at either the end of the PHE or Dec. 31, 2021.


The ATS will provide more detail on both proposed rules in the next issue of the ATS Coding and Billing Quarterly.

Last Reviewed: July 2021