On July 13, CMS released the proposed physician fee schedule for CY 2022. This proposed rule includes updated payment policies, payment rates, and other provisions for services furnished under the Medicare Physician Fee Schedule (PFS) on or after January 1, 2022. CMS is inviting the public to submit comments on this proposed rule until September 13, 2021 before responding with a final rules.

Here are the most critical changes in the CMS proposed fee schedule that PALTC providers need to pay attention to.

1. The conversion factor proposed for 2022 is $33.58.

This is a 3.89% decrease compared to the conversion factor of $34.89 for CY 2021. This decrease is likely to result from the expiration of a 3.75% increase in conversion factor at the end of CY 2021 and budget neutrality adjustment to account for changes in RVUs.

The reduced conversion factor will directly impact reimbursement of Medicare and Medicaid services and negatively affect income for PALTC practices. We hope there will be substantial increases in the RVU’s that can counteract the decrease of the conversion factors and balance the revenue stream of PALTC practices.

If this conversion rate is finalized, PALTC practices will need strong strategies to boost productivity and improve revenue cycle management to reinforce your financial stability.

2. CMS is proposing to expand telehealth and audio-only services for mental health services, especially to those patients who are in rural/underserved communities.

Under this proposal, CMS will reimburse audio-only telehealth services for the diagnosis, evaluation, or treatment of mental health disorders furnished to established patients when the originating site is a patient’s home.

CMS temporarily waived the interactive audio-video requirement for specific mental health and evaluation and management (E/M) services delivered via telehealth for the duration of the public health emergency. This waiver will disappear as soon as the public health emergency expires. With this new proposal, audio-only mental health services will become permanent, reflecting a policy change to better accommodate changing needs of patients.

3. CMS proposed a new set of CPT codes for remote therapeutic monitoring.

These new codes add to the remote patient monitoring codes introduced in 2019, giving providers more ways to get reimbursement for remote patient monitoring services.

The new codes are:

  • CPT code 989X1: initial set-up and patient education on use of equipment
  • CPT code 989X2: device(s) supply with scheduled (e.g., daily) recording(s) and/or programmed alert(s) transmission to monitor respiratory system, each 30 days
  • CPT code 989X3: device(s) supply with scheduled (e.g., daily) recording(s) and/or programmed alert(s) transmission to monitor musculoskeletal system, each 30 days
  • CPT code 989X4: treatment management services, physician/other qualified health care professional time in a calendar month requiring at least one interactive communication with the patient/caregiver during the calendar month, first 20 minutes
  • CPT code 989X5: same as above for each additional 20 minutes

Remote patient monitoring can help PALTC providers achieve the goal of reducing hospital readmissions through accurate tracking of any progress or decline in patient’s health.

4. CMS is proposing to increase performance threshold under the MIPS framework from 60 to 75.

In addition, CMS is also looking to revise reporting requirements and performance categories.


The deadline for submitting comments to CMS on the proposed fee schedule is 5 p.m., September 13, 2021. Saisystems plans on commenting on the proposed fee schedule and will be providing commenting suggestions and templates for the PALTC community in the coming weeks. Stay tuned!


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