On November 2, 2021, the Centers for Medicare and Medicaid Services (CMS) released the calendar year (CY) 2022 Medicare Physician Fee Schedule (PFS) and the Hospital Outpatient Prospective Payment System (OPPS)/Ambulatory Surgery Center (ASC) Final Rules. The rules will be posted in the Federal Register no later than November 19, 2021.
CY 2022 Medicare Physician Fee Schedule Final Rule
Topline Takeaways
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3.71 percent cut to 2022 conversion factor
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New Peroral endoscopic myotomy (POEM) and colon capsule endoscopy CPT codes and payments
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For the 2022 performance year MIPS performance threshold set at 75 points
Payment Charts
Conversion Factor & Impact to Gastroenterology
The final CY 2022 PFS conversion factor is $33.59, a decrease of 3.71 percent. This reduction reflects the expiration of the 3.75 percent increase provided by Congress in the Consolidated Appropriations Act of 2021 Congress’ intervention late last year prevented Medicare physician payment cuts of nearly 10 percent this year. The GI societies continue to work in coalition with national and state medical societies urging Congress to act before January 1, 2022 to extend the 3.75 percent adjustment and to prevent a Medicare sequester next year that could total as much as 6 percent.
New CPT Codes and Values for POEM and Colon Capsule Endoscopy
Beginning January 1, 2022, gastroenterologists can report Peroral Endoscopic Myotomy (POEM) using new CPT code 43497 and colon capsule endoscopy using 91113.
We are disappointed that CMS rejected the AMA RUC recommended 15.50 physician work relative value units (wRVUs) for POEM, finalizing a wRVU of 13.29 for 43497. Our societies are pursuing additional opportunities to engage CMS.
We are pleased CMS finalized the RUC recommended wRVU of 2.41 for new colon capsule endoscopy code 91113. The addition of this new code caused the other capsule endoscopy codes to be reviewed. We are disappointed CMS rejected the AMA RUC recommendation of 1.00 wRVUs for esophageal capsule endoscopy (91111) and finalized 0.90 wRVUs. CMS accepted the RUC recommendation of 2.24 wRVUs for GI tract capsule endoscopy (91110) based on GI survey data, a 10 percent cut.
Merit-based Incentive Payment System
In comments to CMS, our societies asked CMS to keep changes to the Merit-based Incentive Payment System (MIPS) for the 2022 performance year to a minimum. While there was continuity in some requirements and positive evolution of others, citing statutory requirements, CMS finalized its proposal to set the performance threshold for a neutral payment adjustment at 75 points for the 2022 performance year --– a 15-point increase from 2021.
CMS also made clear its intentions to focus the future of MIPS on development of MIPS Value Pathways (MVPs) which are intended to connect activities and measures from the four MIPS performance categories that are relevant to a specialty, medical condition, or a particular population. CMS will introduce seven MVPs to the program beginning with the CY 2023 performance period, none of which are relevant to GI. Our societies continue to engage with CMS on the prospect of developing a well-constructed and well-defined colorectal cancer prevention MVP which would center on screening colonoscopy.
CY 2022 Medicare Hospital Outpatient Prospective Payment and Ambulatory Surgical Center Payment Systems Final Rule
Topline Takeaways
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HOPD and ASC conversion factors will increase 2 percent for those that meet applicable quality reporting requirements
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CMS created a new HCPCS code for ESD (C9779)
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CMS reassigned CPT code 43240 (EGD w/ stent placement) to a new APC with a higher payment
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CMS includes Quality Measure on ASC COVID-19 Vaccination
Payment Charts
Conversion Factors
The final CY 2022 Medicare conversion factor for outpatient hospital departments is $84.177. In accordance with the Medicare statute, CMS is updating the CY 2022 OPPS payment rates for hospitals that meet applicable quality reporting requirements by 2 percent. This update is based on the projected hospital market basket increase of 2.7 percent reduced by 0.7 percentage points for the productivity adjustment.
The final CY 2022 ASC conversion factor is $48.937. In CY 2019, CMS finalized a proposal to apply the hospital market basket update to ASC payment system rates for an interim period of five years (CY 2019 through CY 2023). Using the final productivity-adjusted hospital market basket update, CMS is updating the ASC payment rates for CY 2022 by 2.0 percent for ASCs that meet applicable quality reporting requirements. The GI societies continue to urge CMS to reduce this gap in the ASC facility fees when compared to the outpatient hospital facility rates, which are estimated to be a roughly 50 percent differential in CY 2022.
New HCPCS code for ESD APC Placement of CPT code 43240
CMS created and finalized a new HCPCS code for endoscopic mucosal dissection and set a national payment rate of $2,495.04 in the final rule.
C9779 - Endoscopic submucosal dissection (ESD), including endoscopy or colonoscopy, mucosal closure, when performed; Ambulatory Payment Classification (APC) 5313 (Level 3 Lower GI Procedures)
HCPCS code C9779 is currently not identified as a payable service by Medicare when performed in the ASC setting. CMS did not include HCPCS code C9779 in the proposed rule for comment and no rationale was provided to explain the assignment to an APC with such low payment. The party who requested the code and provided information for its pricing was not identified. Our societies are pursuing additional opportunities to engage CMS on the APC placement of this new code.
APC Placement of CPT code 43240
The GI societies advocated to have CPT 43240 (EGD, flexible, transoral; with transmural drainage of pseudocyst (includes placement of transmural drainage catheter[s]/stent[s], when performed, and endoscopic ultrasound, when performed) reassigned from APC 5303 to APC 5331 due to clinical similarity and costs. CMS agreed. The hospital outpatient payment for CPT 43240 will increase 63% (from $3,161 to $5,160).
ASC Quality Reporting Program
CMS finalized its proposal to adopt the COVID–19 Vaccination Coverage Among Health Care Personnel (HCP) measure (ASC-20). ASCs will need to report data quarterly on the measure starting January 2022. The measure will assess the proportion of an ASC’s health care workforce that has been vaccinated against COVID-19. This measure does not financially reward or punish ASCs for their vaccine coverage rate. An ASC’s payment is affected only if it fails to report the measure, not by the rate it reports. Quarterly, CMS will publicly report the COVID-19 HCP vaccination coverage rate.
Beginning with the 2023 reporting period, CMS will resume data collection for ASC-1: Patient Burn; ASC-2: Patient Fall; ASC-3: Wrong Site, Wrong Side, Wrong Patient, Wrong Procedure, Wrong Implant; ASC-4: All-Cause Hospital Transfer/Admission.
CMS Final Rules and Fact Sheets
