On November 2nd, the Centers for Medicare & Medicaid Services (CMS) issued the final policy updates for the Medicare physician fee schedule payments and policies for 2022 – available HERE.  In this ruling, CMS is finalizing their proposals related to payment policies, the Quality Payment Program (QPP), and again delaying the implementation of the Appropriate Use Criteria/Clinical Decision Support program to 2023 or later.

CLICK HERE for our summary of the main provisions of the Final Rule.

CLICK HERE for our summary on the QPP updates for 2022.

A brief selection of highlights are included below:



CMS opted for a 4 year phase-in of PE RVU changes related to the clinical labor pricing update, lessening the estimated negative impact for specialties like Interventional Radiology and Radiation Oncology
CMS moved forward with a reduction to the conversion factor as previously proposed

Appropriate Use Criteria/Clinical Decision Support

CMS has officially delayed the AUC program until 2023 or later
CMS will create a NEW modifier to indicate claims that are not applicable to the AUC mandate and is exploring using the CCN as an identifier for CAH
At the beginning of the penalty phase, CMS will initially 'return claims' instead of denying them - more details on the process to be announced through the CMS AUC website.
CMS expressed their limited statutory ability in terms of making substantive changes to the structure of the program based on stakeholder feedback, stressing the requirement for congressional intervention to alter major parts of the mandate

Quality Payment Program (MIPS)

CMS has maintained the 3 point floor for the 2022 performance year. CMS will remove the 3 point floor in 2023.
CMS will maintain the data completeness rate of 70% for 2022 AND 2023
CMS finalized the provisions for Small Practices to weight final scores at 50% Quality and 50% Improvement Activities if not scored on Cost. Small Practices will also retain the Small Practice Bonus towards the Quality score
CMS has permanently expanded the Complex Patient Bonus to be worth up to 10 points towards the final score
CMS is establishing a 7-point floor for the first year a brand new Quality measure is introduced to the program and a 5-point floor for the year afterwards - this change makes it easier to adopt new measures without negatively impacting the Quality score
CMS has moved forward with the proposal to raise the penalty level to 75 points for 2022
CMS has removed bonus points for reporting high priority/outcome or EHR based Quality measures
CMS will change the methodology of the Complex PT bonus in 2022 to limit the amount of providers eligible for the bonus
CMS finalized the removal of several important measures for Radiology: 21, 23, 195, and 225

As always, ADVOCATE will keep you up to date on this and all issues impacting medical groups as they become available.

Kayley Jaquet

Manager, Regulatory Affairs