CMS Releases 2022 Physician Fee Schedule Proposal

The Centers for Medicare & Medicaid Services (CMS) released its proposal for the 2022 Physician Fee Schedule and Quality Payment Program rules with a focus on addressing health disparities in vulnerable communities.

Significantly, the fee schedule proposes a 3.75% cut in reimbursements to physicians in order to maintain budget neutrality and also rolls back changes to quality reporting measures finalized last year for participants in the Medicare Shared Savings Program (MSSP).

In a public statement, CMS Administrator Chiquita Brooks-LaSure said that CMS is looking for feedback from providers in alternative payment models (APM) for how they can better collect information on systemic health disparities.

Over the past year, the public health emergency has highlighted the disparities in the U.S. healthcare system, while at the same time demonstrating the positive impact of innovative policies to reduce disparities. CMS aims to take the lessons learned during this time and move forward toward a system where no patients is left out and everyone has access to comprehensive quality health services.

Patient Engagement Hit reports that these efforts will include soliciting comments from APM participants, as at this time accountable care organizations are only responsible for quality reporting on a limited set of Medicare patients. Furthermore, CMS said that it was open to adjusting reporting benchmarks for organizations that treat vulnerable or high-risk populations. It also intends to do these things in a way that protects patient privacy, in the form of confidential health equity reports related to gender and sexual identity, among other significant identity variables.

As part of this effort, CMS proposed to roll back changes made by the prior administration finalized last year for ACO reporting on quality measures. The National Association of ACOs (NAACOS) released a statement expressing its support for the rollback:

NAACOS over the last year has cited potential negative consequences to patient care among the many reasons why such a rapid shift to [electronic clinical quality measure] reporting was bad policy. NAACOS is pleased that the Biden Administration listened to these concerns and is taking actions… The healthcare industry, including ACOs, electronic health record (EHR) vendors and government payers need more time before mandating electronic quality measures, and we are pleased to see CMS provide this necessary transition time.

Physicians are not so pleased with the fee schedule proposal, as it proposed a 3.75% reduction in the conversion factor used to calculate payments to physicians. Medical Economics reports that the cuts are the result of a reduction required to keep Medicare budget neutral. At the end of 2020, Congress passed a one-year delay that prevented cuts from going into effect for another year. From George M. Abraham, M.D., MPH, president, American College of Physicians:

We need to ensure that practices across the country are able to continue to operate and provide frontline care that improves health equity and patient access in their communities. While CMS does not have the authority on their own to correct this, we ask them to support efforts to fix the problem through Congress.

Healthcare Finance reports that the American College of Surgeons (ACS) also argued that the cuts to surgical care in the CMS fee schedule could have dire consequences for health equity as well. It notes that updates to the conversion factor for calculating Medicare payments have not kept up with inflation, which means that the conversion factor is only half of what it would have been if it was indexed to general inflation, as it had been prior to 1998.

CMS Proposed 2022 Physician Fee Schedule