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NAACOS Analysis of the Proposed
2022 Medicare Physician Fee Schedule

Executive Summary

In mid-July, the Centers for Medicare & Medicaid Services (CMS) released the proposed 2022 Medicare Physician Fee Schedule (MPFS) rule. This proposed 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. 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.  

NAACOS is seeking member input on the proposals in this rule, which will help shape our comments. Please share your feedback by emailing us at [email protected]. CMS will review comments and issue a final rule later this year. Typically, the final MPFS rule is released around November 1.

Medicare Shared Savings Program Proposals

  • Provide two additional years to report quality measures using the Web Interface (WI)
  • Phase-in the requirement to move ACOs to electronic clinical quality measure (eCQM) reporting by 2024
  • Freeze the quality performance standard for one additional year
  • Amend the list of primary care services used to assign beneficiaries to ACOs by adding seven more codes starting in performance year (PY) 2022
  • Seek feedback on, without formally proposing changes, to the regional adjustment of MSSP benchmarks, specifically how the agency could account for the removal of ACO-assigned beneficiaries from the regional reference population
  • Ease burdens and costs of ACO repayment mechanisms by cutting in half the percentages used in the existing repayment mechanism amount calculations
  • Reduce MSSP application burden by lowering document submission requirements around prior participation and sample and executed ACO participant agreements
  • Change beneficiary notification requirements for ACOs that select prospective assignment by only requiring notices to be sent to beneficiaries prospectively assigned to their ACO

Medicare Physician Payment Proposals

  • Decrease the Medicare conversion factor to $33.58, a drop of about 3.75 percent
  • Establish a new chronic care management (CCM) code, 99X21, describing CCM services furnished by clinical staff under the supervision of a physician or non-physician practitioner (NPP) who can bill evaluation/management (E/M) services, and CCM services personally furnished by a physician or NPP
  • Continue an ongoing review of E/M visit code sets with clarifications on policies finalized for 2021 and proposals to allow split/shared E/M visits by a physician and NPP in the same group, and to clarify that time a teaching physician is present can count toward E/M visit level for teaching services
  • Retain all of the services temporarily added to the list of those eligible to be delivered via telehealth during the COVID-19 public health emergency (PHE) through the end of 2023,
  • Make a patient’s home a permissible originating site for the diagnosis, evaluation, or treatment of mental health disorders via telehealth, as well as allow tele-mental health to be delivered through audio-only communications
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