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On Nov. 2, 2021, the Center of Medicare & Medicaid Services (CMS) issued the Medicare Physician Fee Schedule (PFS) for Calendar Year (CY) 2022 final rule on behalf of the Department of Health and Human Services. The 2414-page-long document finalizes some across-the-board policy changes that will profoundly impact practice revenues, bringing both potential benefits and negative effects. Out of all those changes, post-acute long-term-care providers and practices should watch these 8 policy adjustments and make necessary preparations to counter any negative impacts and maximize any benefits.

1. CY 2022 Conversion Rates Setting and Conversion Factor

CY 2022 PFS conversion factor is set at $33.59, a decrease of $1.30 from the CY 2021 PFS conversion factor (CF) of $34.89. Two factors contributed to this decrease: expiration of the temporary increase under the Consolidated Appropriation Act, 2021; and mandated net budget neutrality. CAA 2021 expiration will remove the temporary 3.75 percent payment increase. Budget neutrality mandate, on the other hand, reduces CF to neutralize impact of strengthened RVUs and payment increases for some codes.

As a result of a lower conversion factor, long-term-care practices will see a decrease in Medicare payments. Providers need to take immediate actions to mitigate adverse impacts on their revenue in 2022. Improving productivity, optimizing practice workflow to boost efficiency, and increasing collections through strong revenue cycle management are the go-to methods to sustain your revenue through this payment cut.

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2. Split (or shared) E/M Visits

The Physician Fee Schedule final rule refined regulations regarding split (or shared) E/M visits. Split (or shared) E/M visits are defined as E/M visits provided in an institutional setting (point of service that is not outpatient) by a physician and an NPP in the same group. The visit is billed by the physician or practitioner who provides the substantive portion of the visit.

By 2023, the substantive portion of the visit will be defined as more than half of the total time spent. For 2022, the substantive portion can be history, physical exam, medical decision-making, or more than half of the total time (except for critical care, which can only be more than half of the total time). Documentation in the medical record must identify the two individuals who performed the visit. The individual providing the substantive portion must sign and date the medical record.

A claim modifier is mandatory for split (or shared) visits, but CMS did not clarify which modifier will be required.

3. Telehealth Services Under PFS

The Physician Fee Schedule for CY 2022 continues to expand telehealth services. CMS allowed certain services to remain on the list of Medicare telehealth services until Dec. 31, 2022 while the program gathers more data and evaluates the permanent addition of these services following the COVID-10 public health emergency.

The final rule also removed geographic location requirements and allowed patients in their homes access to telehealth services for mental health disorders. CMS included temporary lodging and locations near the patient’s home in its definition of the home. An in-person, non-telehealth visit is required at least every 12 months for these services. Exceptions to the in-person visit requirement may be made based on beneficiary circumstances (with the reason documented in the patient’s medical record). CMS has also added a new place of service to designate telehealth services provided to the patient in their home, POS 10, which is effective on Jan. 1, 2022.

CMS will also permit audio-only communications technology when used for telehealth services for mental health disorders furnished to established patients in their homes under certain circumstances.

4. Chronic Care Management Payment Increase

Despite the across-the-board cut in Medicare reimbursement, chronic care management (CCM) services will see an increase in payment due to the introduction of an expanded set of codes for care management services and adoption of the American Medical Association’s (AMA) RVU Update Committee (RUC) recommendations for relative value assignments.

New codes for care management services include:

– Chronic care management: CPT 99437 – Subsequent 30 minutes, physician or NPP

– Principal care management: CPT 99427– Subsequent 30 minutes, clinical staff and CPT 99425 – Subsequent 30 minutes, physician or NPP

The adoption of the RUC’s recommended RVU increases will bring a significant increase in Medicare reimbursement for these services in 2022, ranging from +$11.70 to +$38.60. CMS is also introducing new reimbursement for remote therapeutic monitoring (RTM) services in 2022. RTM involves non-physiologic data, which can be self-reported by the patient to the billing practitioner, such as medication adherence. These are general medicine codes, which can be billed by providers who cannot bill for evaluation and management codes.

In many cases, providers are already meeting the requirements for billing chronic care management but may not have the clinical tools to report and bill for it. The good news is that an advanced EHR built for post-acute long-term care can help you easily claim this reimbursement.

Check out how PacEHR electronic record can help you document your CCM services and bill for them in just 2 clicks. Don’t let poor EHR stop you from increasing your revenue.

5. Billing for Physician Assistant Services

Medicare currently can only make payments to the employer or independent contractor of a PA. Beginning Jan. 1, 2022, for the first time PAs may bill Medicare directly for their professional services, reassign payment for their professional services, and incorporate with other PAs and bill Medicare for PA services.

6. Medicare Provider Enrollment

The final rule also expands CMS’ authority to deny or revoke a provider’s or supplier’s Medicare enrollment and establish a rebuttal procedure for those whose Medicare billing privileges were .

 7. Opioid Treatment Program (OTP) Payment

In the PFS CY 2022, CMS finalized that it will continue to pay for counseling and therapy services via audio-only interactions even after the end of the COVID-19 pandemic. OTPs are required to use a service-level modifier for audio-only services under the counseling and therapy add-on code.

CMS also issued an interim final rule with comment to maintain the payment amount for methadone at the CY 2021 rate for CY 2022. This is to avoid negative impacts on methadone access due to decreased payment amount. Meanwhile, CMS is seeking comments on the utilization pattern of methadone for OTPs beneficiaries and any applicable data.

8. Therapy Services Payment

The PFS for CY 2022 finalized the 15% cut to payment for physical therapy and occupational therapy services provided in whole or part by physical therapy assistants (PTA) or occupational therapy assistants (OTAs). This cut will apply to service dates on or after Jan. 1, 2022.

The payment cut will be implemented through the use of new modifiers, CQ and CO. CMS also revised its de minimis policy to define which services will the payment cut apply to. Specifically, a 15-minute timed service can be billed without the CQ/CO modifiers when a PTA or OTA participates in providing care, independent of the PT/OT, but the PT/OT provides more than the 15-minute mid-point (8 minutes).

De minimis standard also applies to the case of two 15-minute units. If the PT/OT and the PTA/OTA each provide between 9 and 14 minutes of the same service, totaling between 23 and 28 minutes, one unit can be billed without the CO/CQ modifier.

Conclusion

The CMS Physician Fee Schedule CY 2022 final rule will bring many changes to Medicare payment in 2022 and significantly impact the income of post-acute long-term care practices. Some of the changes will increase your revenue; others will reduce your reimbursement. To maximize the benefits of positive changes and mitigate any negative impacts, practices need to start an action plan now and be ready to implement by January 2022. Act now before payment cut impacts your revenue.

 

Saisystems can help you uncover operational weaknesses and form a successful strategy to increase collection, improve efficiency and drive productivity. Talk to us now for a discovery session.