Article Item

Comments on Medicare Payment Policies: Conversion Factor, Labor Pricing, Telehealth, and More

Oct 18, 2021

ASRA
Medicare

In a September 13th letter to the Centers for Medicare and Medicaid Services (CMS), ASRA provided comments regarding the Medicare Program; Calendar Year (CY) 2022 Payment Policies under the Physician Fee Schedule (PFS) and Other Changes to Part B Payment Policies; Medicare Shared Savings Program Requirements; Provider Enrollment Regulation Updates; Provider and Supplier Prepayment and Post-payment Medicare Review Requirements.

ASRA made the following recommendations:

  • Urged CMS to work with Congress to mitigate the reduction in the PFS conversion factor for 2022 and to eliminate payment reductions associated with sequestration of Medicare payments
  • Recommended updates to clinical labor pricing using a four-year transition more frequent pricing data updates
  • Recommended CMS work with Congress to eliminate the statutory geographic restrictions and originating site requirements that apply to Medicare telehealth services
  • Supported CMS’s proposal to retain all Category 3 services on the Medicare telehealth services list until the end of 2023
  • Recommended that CMS add CPT codes 95970 through 95972 to the Medicare telehealth services list on a Category 3 basis
  • Urged CMS to expand the definition of interactive telecommunications system to include audio-only communications technology when used to furnish evaluation and management (E/M) services.
  • Recommend CMS adopt the RVS (relative value system) Update Committee-recommended values for the following CPT codes:
  • Destruction by neurolytic agent (CPT codes 64633, 64634, 64635, and 64636)
  • Destruction of intraosseous basivertebral nerve (CPT codes 646X0 and 646X1)
  • Supported CMS’s efforts to provide separate or add-on coding and payment for chronic pain management services
  • Requested that CMS demonstrate the value of the Merit-based Incentive Payment System (MIPS) on improving quality and controlling costs under the Medicare program, including as envisioned under its MVP proposals, before implementing substantive changes.
Read the entire letter.
Close Nav