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

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.