NAACOS Analysis of the Final 2022 Medicare Physician Fee Schedule

Executive Summary

In November, the Centers for Medicare & Medicaid Services (CMS) released the final 2022 Medicare Physician Fee Schedule (MPFS) rule. This regulation includes a number of policies affecting Medicare physician payment, quality measure and reporting changes for Medicare Shared Savings Program (MSSP) ACOs, and Quality Payment Program (QPP) requirements for 2022. NAACOS submitted comments in response to the proposed 2022 MPFS rule in September. The key proposals affecting ACOs are outlined below and further detailed in this analysis. The rule is summarized in this CMS factsheet along with detailed QPP changes.   

Medicare Shared Savings Program Policies

• Delay the electronic Clinical Quality Measure (eCQM) requirement for ACOs for three years to 2025
• Postpone the increase in the MSSP quality performance standard threshold for one additional year to 2024
• Finalize a minimum performance threshold of 75 points for Merit-Based Incentive Payment System (MIPS) for 2022 and an exceptional performance threshold of 89 points
• Finalize no changes to the performance category weights for ACOs subject to MIPS
• Finalize updates to the list of primary care services used to assign beneficiaries to ACOs by adding seven codes starting in performance year (PY) 2022
• Decline to make formal changes for now to the regional adjustment of MSSP benchmarks and risk adjustment methodologies
• Reduce MSSP application burden by lowering document submission requirements
• Update beneficiary notification requirements for ACOs that select prospective assignment 

*Denotes policies for which NAACOS has long advocated 

Medicare Physician Payment Policies

• Decrease the Medicare conversion factor to $33.598, from $34.89, which was finalized for 2021, a drop of about 3.8 percent
• Add new chronic care management (CCM) code, 99437, which describes each additional 30 minutes by a physician or other qualified health care professional, per calendar month, along with four additional new principal care management services and increasing payment for certain CCM services including 99490
• Establish a patient’s home as a permissible originating site for the diagnosis, evaluation, or treatment of mental health disorders via telehealth, as well as allows tele-mental health to be delivered through audio-only communications
• Finalize the addition of five new “remote therapeutic monitoring” codes in 2022 to cover the collection and interpretation of “non-physiologic” patient data
• Revise evaluation and management (E/M) policies regarding split/shared visits, critical care services, and teaching physician visits