On July 13, 2021, CMS released their proposed Calendar Year (CY) 2022 Medicare Physician Fee Schedule.Below is a summary of key payment and policy changes within the rule. Comments are due by September 13, 2021.

Physician Fee Schedule

Please find our summary of the PFS here

Please find some topline elements and links below.  

On July 13, 2021, CMS issued the proposed Calendar Year 2022 (CY2022) Physician Fee Schedule (PFS), which makes payment and policy changes under Medicare Part B.

CMS is proposing to retain all services added to the Medicare telehealth services list on a Category 3 basis until the end of CY 2023 – December 31, 2023 – to allow for time to collect more information regarding utilization of these services during the pandemic, and provide stakeholders the opportunity to continue to develop support for the permanent addition of appropriate services to the telehealth list through the regular consideration process, which includes notice-and-comment rulemaking.

In addition, CMS is proposing to amend the current regulatory requirement for interactive telecommunications systems to include audio-only communication technology when used for telehealth services for the diagnosis, evaluation, or treatment of mental health disorders furnished to established patients in their homes. CMS is proposing to limit the use of an audio-only interactive telecommunications system to mental health services furnished by practitioners who have the capability to furnish two-way, audio/video communications, but where the beneficiary is not capable of using, or does not consent to, the use of two-way, audio/video technology.

Finally, CMS is proposing to require an in-person visit be provided by the physician or practitioner furnishing mental health telehealth services within six months prior to the initial telehealth service, and at least once every six months thereafter.

  • CMS is seeking comment on whether a different interval may be necessary or appropriate for mental health services furnished through audio-only communication technology.
  • CMS is also seeking comment on how to address scenarios where a physician or practitioner of the same specialty/subspecialty in the same group may need to furnish a mental health service due to unavailability of the beneficiary’s regular practitioner.

CMS is also soliciting comment on: (1) whether additional documentation should be required in the patient’s medical record to support the clinical appropriateness of audio-only telehealth; (2) whether or not CMS should preclude audio-only telehealth for some high-level services, such as level 4 or 5 E/M visit codes or psychotherapy with crisis; and (3) any additional guardrails CMS should consider putting in place in order to minimize program integrity and patient safety concerns.

Please see our detailed summary of the proposed rule below:

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