In the new final rules, CMS announced several policies for E/M code sets.
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On November 2, 2021, the Centers for Medicare & Medicaid Services issued its 2022 final rule to update policy and payment changes as of January 1, 2022. The overarching goal touted by CMS is to create a health care system that results in better accessibility, quality, affordability, and innovation. Some of the more impactful changes are listed below. The full final rule can be accessed here.
Reductions in the Physician Fee Schedule (PFS)
The PFS dictates Medicare payment rates for many types of physician services with relative value units (RVUs), which are based on the resources typically used to provide the service. By applying the fixed dollar conversion factor listed in the 2022 PFS, rates are determined across the board. In 2021, PFS were temporarily raised by 3.75% to provide some measure of COVID-19 relief. That increase is set to expire and will not be renewed. The PFS conversion factor adjustment effectively decreases the payment amount from $34.89 in 2021 to $33.59 per RVU in 2022.
Split or Shared E/M Visits
CMS announced several policies for E/M code sets, reflecting 2021 changes in the AMA CPT Codebook, including refining policies for split or shared E/M visits to better reflect current practice.
The practitioner who performs the substantive portion of the visit — defined as more than 50% of time spent — will bill for the entire visit. The record must reflect the shared nature of the visit and must be signed by the provider conducting the substantive portion of the visit. This may particularly affect physician and mid-level provider arrangements and payment. A special modifier will be added to these codes for data collection and program assessment.
Critical Care Services
In 2022, critical care visits may be paid on the same day as other E/M visits by the same provider or another provider in the same group and same specialty. The critical care visit must be a new development and be unrelated to the initial E/M visit. Another modifier will be attached to these codes for tracking purposes.
Telehealth Services Renewed
As the pandemic unfolded in 2020, many telehealth services were temporarily added to the list of CMS paid services in order to provide necessary care. These services have been renewed until December 31, 2023, allowing CMS additional time to evaluate if they should be permanently added.
MIPS Categories
Changes have been announced for the four MIPS categories: quality, cost, promoting interoperability, and improvement activities. The minimum performance threshold for MIPS has increased from 60 points in 2021 to 75 points in 2022. After a couple of difficult years, this may prove challenging to many physician practices.
Meeting the Challenge
When an ancient Greek philosopher said, “The only constant in life is change,” he could have been talking about health care today. And, all of these CMS changes point to the importance of using emergency medicine performance analytics.
Over the past two years, many health care systems have tightened their financial belts to the last notch and need to find new opportunities and efficiencies to stay afloat. d2i provides targeted strategies based on individual data patterns, enabling specific action plans for success in the 2022 environment.
New rules require new adaptations, and to form those action plans HCOs need a solid data strategy. Contact d2i to find out how analytics helps to maximize appropriate reimbursement and MIPS incentives while also improving efficiency and patient safety.