ACC Comments on CMS 2022 Medicare Physician Fee Schedule Proposed Rule

The ACC has submitted a comment letter to the Centers for Medicare and Medicaid Services (CMS) on the proposed 2022 Medicare Physician Fee Schedule. The letter addresses payment policy and technical changes that drive payment for individual services, as well as other programmatic topics related the Quality Payment Program, Merit-Based Incentive Payment System (MIPS) Value Pathways (MVPs) and others outlined for 2022.

The ACC recommends CMS not finalize two broad proposals that would have unintended consequences. The first would require billing of split/shared visits by physicians and advanced practice providers exclusively by time. The second would increase practice expense costs for clinical staff labor in a manner that precipitously reduces payment for other services. Proposed work relative value unit (RVU) reductions that result from bundling several services involved in electrophysiology ablation are also addressed in detail, with the ACC urging caution, accuracy and a phase-in of any significant reductions that may still occur.

The letter includes comments from the College on the first detailed proposals for MVPs that were included in this 2022 rulemaking cycle. The ACC supported efforts to streamline quality reporting and steps toward alternative payment models but urged caution in telling CMS the agency should not finalize a plan to sunset the existing MIPS program at the end of 2027 with a requirement for mandatory reporting through MVPs at this time. In a similar vein, the College expressed support for progress in the movement toward standardization in digital quality measurement but indicated that a move to full digital quality measurement reporting by 2025 places undue burdens and costs on the system and clinicians.

Finally, the ACC supported several narrower proposals, such as the removal of an outdated national coverage determination that has limited myocardial PET in some instances and delay of claims processing system edits and the penalty phase of the Appropriate Use Criteria Program due to the COVID-19 public health emergency.

CMS is expected to release the final 2022 Medicare Physician Fee Schedule rule by Nov. 2. Before that occurs, join your colleagues at ACC's Legislative Conference, Oct. 3-5, to learn about current advocacy priorities and ensure your voice is heard by Congress.

Clinical Topics: Arrhythmias and Clinical EP, Cardiovascular Care Team, Noninvasive Imaging, Implantable Devices, SCD/Ventricular Arrhythmias, Atrial Fibrillation/Supraventricular Arrhythmias, Computed Tomography, Nuclear Imaging

Keywords: Centers for Medicare and Medicaid Services, U.S., Mandatory Reporting, Public Health, COVID-19, Medicare, Fee Schedules, Physicians, Policy, Electrophysiology, Positron-Emission Tomography, SARS-CoV-2, ACC Advocacy


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