Late July 13, 2021, the Centers for Medicare and Medicaid Services (CMS) issued the proposed Medicare Physician Fee Schedule (MPFS) Rule for 2022. Based on an initial review of the proposed rule, below are some key provisions of interest to audiology.
The 2022 Medicare conversion factor is $33.5848, down from $34.8931. This is largely due to the expiration of a 3.75 percent increase to the conversion factor at the end of calendar year 2021, a cut averted for 2021 by Congressional action. Congressional action will be necessary to avert the cut for 2022. The Academy will continue to engage in collaborative efforts with other health care disciplines to seek the needed legislative action to maintain the increase to the conversion factor, at least through CY22.
CY 2022 MPFS Estimated Impact on Total Allowed Charges by Specialty
CMS estimates the impact on Audiology to be -1 percent. However, it is unclear if the impact table published by CMS includes the 3.75 percent reduction in the conversion factor. Based on verbal feedback provided by CMS in its July 15, 2021, afternoon forum on the CY 2022 proposed rule, CMS indicated it did account for the expiration of the 3.75 percent payment correction. However, there is still some uncertainty with the CMS data, as evidenced in the fact that CMS published revised data tables on July 15, 2021. Audiology numbers were re-calculated to ensure there were no changes in our initial calculations for audiology services.
In a late update from July 16, 2021, the American Medical Association states it confirmed with CMS that the 3.75 percent cut is not included in the specialty impact tables for 2022. The Academy will seek to confirm this information and communicate an update to members as information becomes available.
Extension of Covered Telehealth Services
There were no changes proposed for audiology telehealth services. However, it should be noted that CMS stated that they lack the statutory authority to maintain the telehealth flexibilities allowed during the federal public health emergency (PHE). Therefore, audiologists will no longer receive Medicare reimbursement for telehealth services when the PHE ultimately expires.
Merit-Based Incentive Payment System (MIPS)
CMS proposes extensive changes in MIPS, namely the current MIPS program would sunset at the end of the 2027 performance and submission period.
CMS proposes to implement its MIPS Value Pathways (MVP) framework beginning in 2023, with seven options for participation in the first year. Participation would be voluntary. The initial MVP clinical areas include:
- stroke care and prevention,
- heart disease,
- chronic disease management,
- lower extremity joint repair (e.g., knee replacement),
- emergency medicine, and
The goal of MVPs is to more effectively measure and compare performance across clinician types and provide clinicians with more meaningful feedback.
More analysis of the MVP framework is needed to understand implications for audiologists as the program evolves. More information will be posted as analysis of the proposed rule continues. The Audiology Quality Consortium, chaired by the Academy, will have a significant role in reviewing the changes as proposed in this rulemaking.
For audiology specifically, CMS proposes:
Removal of Measure 154 (Falls Risk Assessment) from the audiology MIPS measures specialty set. CMS propose to remove this measure because it is “topped out,” meaning the performance is high and CMS sees little opportunity to improve clinical outcomes.
Maintaining the exemption for audiology from the “promoting interoperability” and cost performance categories. Other MIPS performance categories (Quality and Improvement Activities) would be re-weighted to calculate the score for a participating audiologist.
On July 19, 2021, the Centers for Medicare and Medicaid Services (CMS) posted the proposed rule on the 2022 Hospital Outpatient Prospective Payment System. The Academy is reviewing the proposed rule for any policy changes that would affect the provision of audiology services in the outpatient setting. The Academy has calculated proposed reimbursement for audiology…
2022 Proposed Medicare Physician Fee Schedule – Initial Calculations of Proposed Payment Rates for Audiology Services
On July 13, 2021, CMS issued the Notice of Proposed Rule Making for the CY 2022 Medicare Physician Fee Schedule (MPFS). The Academy payment policy team has organized a chart of the proposed payment rates for audiology service (see “Current Resources”) based on initial calculations. Staff will continue analysis and post additional guidance. 7.13.21 CY…
The Centers for Medicare and Medicaid Services (CMS) has issued this afternoon the Notice of Proposed Rule Making (NPRM) for the 2022 Medicare Physician Fee Schedule. Review the notice on the Federal Register website. CMS has issued a press release on the NPRM, as well as a fact sheet. The Academy is beginning its analysis of the Proposed Rule…