Final 2022 Physician Fee Schedule

CMS released the final 2022 Medicare physician fee schedule rule on November 2, 2021. The new rates take effect on January 1, 2022. CMS estimated the policy changes in the rule will have a zero effect on the allergy/immunology specialty overall. However, this does not account for the 3.85% reduction in the conversion factor – see details below. The College submitted detailed comments on the proposed rule and thanks CMS for incorporating our feedback.

Below is a summary of the issues important to the allergy/immunology specialty.

Medicare payment rates: There is an across-the-board reduction in the conversion factor of 3.85%, largely due to the expiration of the 3.75% increase enacted by Congress last year to help providers during the public health emergency (PHE). The decrease results in a conversion factor of $33.5983, down from $34.8931 in 2021. Review the impact on allergy services, by code.

The College continues to strongly advocate for Congress to avert this significant cut and extend the 3.75% increase for 2022. Voice your support at the College booth in New Orleans, where you can sign on to our letter to Congress.

Clinical Labor Price Update: CMS is updating the clinical labor cost portion of the Medicare practice expense RVUs. Because of budget neutrality, this has a negative impact on services that receive most of their payment from supply costs including allergy immunotherapy and skin testing, which derive a substantial portion of their payment from the costs of the allergenic extracts. CMS had proposed to implement the cost updates all in one year, but as a result of College advocacy, decided to phase in the changes over 4 years instead.

New Remote Therapeutic Monitoring Codes: CMS has finalized its proposal to cover and price five new remote therapeutic monitoring (RTM) codes created by the CPT Editorial Panel in October of 2020. One of the codes is specifically for respiratory therapy and has been used in connection with devices that monitor inhaler usage by asthma patients. Allergists who use this device or other devices to remotely monitor a patient’s asthma or other conditions can be paid for both the technical service (e.g., device, transmission) and their professional treatment management.

The new codes include two technical-component-only codes and two that include professional work. This code family is similar to the existing remote physiological monitoring (RPM) codes and are billable every 30 days. Medicare reimbursement is as follows:

Payment for Audio-Only Telehealth Visits:  CMS will not extend payment for audio-only telehealth services beyond the duration of the PHE with the exception of mental health services. Therefore, when the PHE ends, telehealth services will only be reimbursed if they make use of audio and visual technology.

Increase in payment for vaccine administration: CMS will pay $30 per dose for the administration of influenza, pneumococcal, and hepatitis B vaccines in 2022 and will continue to pay $40 for COVID-19 vaccine administration through the end of the year in which the PHE ends.

Physician Assistant Billing Rights: Beginning January 1, 2022, physician assistants will be able to bill Medicare directly rather than having their services billed by their employer. This will allow physician assistants to form their own practice groups and work in a collaborative arrangement with a physician to the extent permitted by state law.

MIPS Asthma/Chronic Obstructive Pulmonary Disease (COPD) Cost Measure: CMS is adding a new MIPS chronic condition cost measure—Asthma/COPD—beginning with the 2022 performance period.

MIPS Performance Threshold: For the 2022 performance period, CMS will increase the performance threshold to 75 points and the exceptional performance threshold to 89 points. The 2022 performance period is the last year of the additional performance threshold and the associated additional payment adjustment factors for exceptional performance.

MIPS Performance Category Weights: For the 2022 performance period and beyond, for individuals, groups, and virtual groups, CMS will weigh the performance categories as follows:

• 30% for the Quality and Cost performance categories; (a 10% decrease from 2021 for Quality, and a 10% increase from 2021 for Cost)
• 25% for the Promoting Interoperability (PI) performance category (same as 2021)
• 15% for the Improvement Activities (IA) performance category (same as 2021).

Small Practices: Beginning with the 2022 performance period, small practices will no longer need to submit a MIPS hardship exception application to request reweighting of the PI performance category.  However, if a small practice submits PI data, CMS will score the data.  CMS finalized the following redistribution policies for small practices beginning with the 2022 performance period:

• If the PI performance category is reweighted, CMS will weight:
  • The Quality performance category at 40%.
  • The Cost performance category at 30%.
  • The IA performance category at 30%.
• If the PI and Cost performance categories are reweighted, CMS will weight:
  • The Quality and IA performance categories at 50%.

Beginning with the 2022 performance period, small practices (except those participating in MIPS as part of a virtual group) are required to submit data as a group in any performance category to indicate that they wish to be scored as a group for Medicare Part B claims.

Complex Patient Bonus: For the 2021 performance period, CMS will continue to double the complex patient bonus, with a cap of 10 bonus points. Beginning with the 2022 performance period, CMS will update its formula for the complex patient bonus and increase the bonus to a maximum of 10 points.

MIPS Value Pathways (MVPs): MVP reporting will begin in 2023 but will be optional; practices can still report using the traditional MIPS program. There are currently no MVPs specific to allergy/immunology.

The Advocacy Council – we have you covered.