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Medicare Physician Fee Schedule

The Centers for Medicaid and Medicare Services (CMS) released the calendar year (CY) 2022 Medicare Physician Fee Schedule (MPFS) final rule on November 2^nd. The SVU has created this initial review of provisions within the final rule that affect vascular lab reimbursement.

Conversion Factor

The CY 2022 conversion factor is $33.59 compared to the 2021 conversion factor of $34.89. The conversion factor reflects the statutory update of zero percent and the adjustment necessary to account for changes in relative value units (RVUs) and expenditures that would result from finalized policies. Last year, Congress provided a 3.75 percent payment increase to avert significant Medicare physician payment cuts. This provision is set to expire at the end of 2021 unless Congress steps in again.

Clinical Labor Pricing Update

CMS is moving forward with the 4-year implementation of the clinical labor pricing updates, beginning 2022 and ending in 2025. CMS has revised their initial proposed methodology:

• CMS will apply the 2019 fringe benefits multiplier (1.296) instead of using the 2002 benefits multiplier (1.366).
• CMS will use median wage data instead of the mean wage data.

FINAL Clinical Labor Pricing Update

Relevant Links:

• CMS-1751-F (PFS CY 2022)
• CMS Fact Sheet PFS CY 2022

Hospital Outpatient Prospective Payment System (OPPS)

CMS also released the CY 2022 OPPS final rule with comment period on November 2^nd. Most of the vascular lab codes fall into one of these two ambulatory payment classifications (APC).

Relevant links:

• CMS-1753-FC (OPPS CY 2022)
• CMS Fact Sheet OPPS CY 2022

Impact of rulemaking on vascular lab codes and reimbursement

The SVU Advocacy Committee has prepared this spreadsheet to help members understand the impact of provisions within the final rule on reimbursement.

There are a couple pieces of legislation that may impact reimbursement too.

The first is the Medicare sequestration payment reduction. The 2011 Budget Control Act (BCA) mandated federal budget cuts over nine years to reduce the deficit. This included annual 2% cuts to Medicare payments, also known as Medicare sequestration. However, this sequester has proven to be a popular offset and has been extended by Congress through fiscal year 2030. Due to the COVID-19 pandemic and its effect on physicians and other health care providers, Congress passed legislation to extend the moratorium on this sequester through December 31, 2021. Without action, the 2% reduction in reimbursement for all Medicare services will be reinstated on January 1, 2022.

The second piece of legislation worth mentioning is the Statutory Pay-As-You-Go (PAYGO) Act of 2010. PAYGO requires, among other things, that mandatory spending and revenue legislation not increase the federal budget deficit over a 5- or 10- year period. Should such legislation be enacted without offsets, the Office of Management and Budget (OMB) is required to implement sequestration, or across-the-board reductions, in certain types of mandatory federal spending.

The Congressional Budget Office has estimated that a PAYGO sequester in fiscal year 2022 resulting from passage of the American Rescue Plan Act of 2021, the $1.9 trillion COVID-19 relief package passed this March, would cause a 4% reduction in Medicare spending – or cuts of approximately $36 billion. This 4% cut to Medicare payments could go into effect if Congress does not act.