2022 CMS FINAL RULE
On November 5, 2021, the Centers for Medicare and Medicaid Services (CMS) published the 2022 Physician Fee Schedule Final Rule. The final rule governs payment rates and other critical reimbursement issues for dates of service beginning on January 1, 2022. The final rule can be found on the LogixHealth website, www.logixhealth.com.

Additionally, LogixHealth has released a comprehensive review of the final rule in its 2022 ED Physician Update. The CMS 2022 final rule was published in the Federal Register and can be found on the LogixHealth website. Below are some highlights from this newsletter.
“Congress has acted and provided 3.00% in new funding to support the 2022 conversion factor.”

- Elijah Berg, M.D., CEO of LogixHealth
2022 CONVERSION FACTOR
At the conclusion of 2021, the Medicare conversion factor (the amount Medicare pays per RVU) was set at $34.8931. The 2022 final rule, as in past years, is subject to “budget neutrality,” a previously obscure factor which is becoming increasingly impactful.

Due to exceptionally large 2021 increases in the RVUs for the office visit evaluation and management (E/M) codes (99201-99215), and the corresponding increases in payments for office-based services, the budget neutrality adjustment was triggered and the conversion factor has been driven down significantly in order to preserve budget neutrality. Congress, at the end of 2020 provided 3.75% in new money to support the 2021 conversion factor as a one-year fix. The 2022 final rule initially published a conversion factor of $33.5983. Subsequently, Congress provided 3.00% in new funding to support the 2022 conversion factor. On December 20, 2021, CMS published an updated higher conversion factor of $34.6062.
2022 RVUS FOR ED/EM SERVICES
In 2018, CMS recommended that the American Medical Association’s Relative Value Update Committee (RUC) potentially revalue the work RVUs associated with the ED evaluation and management (E/M) CPT codes (99281-99285). The ACEP RUC representatives developed robust arguments supporting the higher acuity of ED patients and the additional resources required to care for sicker patients with greater comorbidities leading to back to back increases in 2020 and 2021. Following these meaningful annual increases, the 2022 ED RVUs are stable, with minimal changes.
MERIT-BASED INCENTIVE PAYMENT SYSTEM (MIPS)
The Merit-Based Incentive Payment System (MIPS) represents a payment mechanism that provides for annual reimbursement adjustments related to quality program requirements impacting 2024 payments based on 2022 performance in four categories:

  • Quality
  • Cost
  • Improvement Activities
  • Promoting Interoperability- previously Meaningful Use of an Electronic Health Record (EHR) System

LogixHealth's 2022 ED Physician Update details the latest MIPS program requirements.
CPT CHANGES FOR EMERGENCY MEDICINE IN 2022
There are no significant changes in the E/M code section of CPT directly impacting emergency medicine in 2022. However, the office visit code E/M section (e.g., Urgent Care) was fully rewritten last year (2021) with significant changes.
 
The ED documentation and coding requirements have not changed for 2022, but are likely to change for 2023. Organized emergency medicine is providing input to CPT and CMS regarding possible changes. The LogixHealth policy team will keep you informed of developments.

Telemedicine updates are also provided in LogixHealth's 2022 ED Physician Update.
LOGIXHEALTH 2022 PHYSICIAN UPDATE