The Centers for Medicare and Medicaid Services (CMS) published its proposed 2022 Medicare Physician Fee Schedule on July 13, 2021. During 2021, because of a Congressionally mandated increase in the conversion factor, overall Medicare reimbursement for allergists increased. Because of budget neutrality requirements, the proposed 2022 reimbursement reflects a decrease in the conversion factor and an overall impact on allergy of -5.3%.
CMS is accepting public comments on its proposal until September 13, 2021, and the Advocacy Council will be submitting comments on behalf of our members on this and all issues affecting allergy. A future Advocacy Insider article will address changes to the Quality Payment Program and Merit-based Incentive Payment System (MIPS).
Budget neutrality adjustment of minus 3.75%: Because of budget neutrality requirements in the law, all services are scheduled to undergo payment reductions of 3.8% across the board. Similar reductions had been scheduled for 2021, but Congress stepped in and passed legislation allowing for a 3.75% payment increase for 2021, neutralizing the reduction. The expiration of that law requires CMS to implement budget neutrality rules which result in a reduction of the Medicare conversion factor (the dollar amount by which a service’s relative value units are multiplied) from $34.89 to $33.58. While there is some possibility that Congress could intervene again to prevent this reduction from taking effect, there is no guarantee. The Advocacy Council will strongly advocate that Congress avert this significant cut and extend the 3.75% increase for 2022.
Other changes impacting payment for allergy services: CMS is also proposing additional changes that, if adopted, would contribute to significant payment reductions for many allergy services. These potential cuts are largely the result of a proposal to update and increase wages of clinical labor which have not been updated since 2002. Clinical labor is one factor in the formula CMS uses to calculate reimbursement. Because Medicare payments are subject to budget neutrality requirements, increasing payment for clinical labor puts more dollars in the labor pool, which decreases the dollar pool for supplies. Since reimbursement for allergy testing and immunotherapy is composed largely of antigen costs (which are considered “supplies”), payment for allergy services is negatively impacted as dollars are moved into the clinical labor category. CMS is considering implementing this change over four years, which would mitigate its impact. The Advocacy Council will be submitting comments on this issue.
New code and coverage for remote monitoring of respiratory function: CMS is also proposing to cover five new CPT codes for remote therapeutic monitoring, including monitoring of the respiratory system. The new codes are billable every 30 days. Medicare is proposing to pay approximately $51 for treatment management and approximately $45 for digital monitoring of a patient’s respiratory system. It would be possible to bill both codes where data is collected digitally via a device. These codes could be billed every 30 days for as long as the patient needs to have respiratory function monitored.
More information on the 2022 proposed fee schedule:
Watch for the Advocacy Insider article addressing changes to the Quality Payment Program and Merit-based Incentive Payment System (MIPS). The Advocacy Council – we have you covered!