Advocacy Update

Aug. 13, 2021: Advocacy Update spotlight on 2022 Physician Fee Schedule proposed rule summary


On July 13, the Centers for Medicare and Medicaid Services (CMS) released the Calendar Year (CY) 2022 revisions to payment policies under the Physician Fee Schedule (PFS) and other changes to Part B payment policies proposed rule (published in the Federal Register on July 23: Docket number CMS-1751-P).

In addition, CMS published a fact sheet on the PFS proposed rule highlighting the key provisions. If finalized, the proposed policies in the rule will take effect on Jan. 1, 2022. CMS is requesting that comments be submitted no later than Sept. 13. The proposed rule covers diverse topics, including the CY 2022 Rate Setting and Medicare Conversion Factor, Evaluation and Management (E/M) office visit services, telehealth and other services involving communications technology and updates to the Quality Payment Program through Merit-based Incentive Payment System (MIPS) activities, methodology, payment adjustments and the Promoting Interoperability performance category, among other provisions. The proposed CY 2022 PFS conversion factor is $33.58, a decrease of $1.31 from the CY 2021 PFS conversion factor of $34.89. This represents a 3.75% decrease in the conversion factor compared to last year. The proposed CY 2022 anesthesia conversion factor is $21.04, a decrease of $0.52 from the CY 2021 anesthesia conversion factor of $21.56.

These CMS proposed conversion factors include the budget neutrality adjustment from the 2021 implementation of improved payments to Evaluation and Management (E/M) office visits. Under the Medicare Access and CHIP Reauthorization Act (MACRA), the statutory physician payment update for CY 2022 is zero percent. Further, the budget neutrality adjustment will be required in 2022 to offset the payment increases for office visits. The consensus of the AMA and the Federation is that the budget neutrality adjustment must continue to be waived in light of the continued COVID-19 public health emergency (PHE) and the AMA strongly urges Congress to waive the budget neutrality payment reduction of 3.75%.

Read the full proposed rule summary (PDF).