The U.S. Centers for Medicare and Medicaid Services (CMS) on July 13 released a proposed rule for the 2022 Medicare Physician Fee Schedule (MPFS) that includes some cuts to radiology reimbursement -- although much less severe than the 10% initially slated for 2021.
The rule proposes a conversion factor of $33.58, down almost 4% compared with 2021's $34.89, and an overall cut to reimbursement for radiology of 2%, with some subspecialties, such as interventional and radiation oncology, sustaining deeper cuts.
| Impact of CMS proposed 2022 MPFS on radiology payments | |
| Subspecialty | Payment decrease |
| Interventional radiology | 9% |
| Radiation oncology and radiation therapy centers | 5% |
| Nuclear medicine | 2% |
"The Consolidated Appropriations Act of 2021 ... included a 3.75% adjustment to the 2021 conversion factor which rolled back the payment cuts to radiologists from 10% to approximately 4%," the American College of Radiology (ACR) said in a statement regarding the proposed rule. "[But] if Congress does not intervene, the percent decreases ... could be greater for calendar year 2022 for many physicians, including interventional radiology and radiation oncology."
The proposed document continues the agency's 2020 plan to adopt a new, higher-valued coding structure for office/outpatient evaluation and management codes as well as values recommended by the Relative Value Update Committee.
As for appropriate use criteria (AUC) and clinical decision support, the proposed document recommends moving forward with Medicare's AUC program for advanced diagnostic imaging, with the penalty phase to begin January 1, 2023 -- or the first year after what it calls the COVID-19 "public health emergency" ends.
"CMS recognizes the significant hardships faced by hospitals and medical practices during the pandemic as well as the investment that many practices have already made in AUC systems," the ACR wrote. "When fully implemented, the AUC program will be a valuable tool to ensure that Medicare patients receive the right imaging at the right time."
The document also continues efforts by CMS to refine its Quality Payment Program, specifically its Merit-based Incentive Payment System (MIPS) Value Pathways (MVPs) program, proposing a further delay of implementation of MPVs until 2023. Additionally, the agency is proposing 2022 category weights for the MIPS program of 30% for quality (down from 40% in 2021), 30% for cost, 25% for promoting interoperability, and 15% for improvement activities.
The proposed rule acknowledges that the COVID-19 pandemic will continue to affect clinicians through the rest of 2021, and it invites individual physicians and physician groups to apply for Extreme and Uncontrollable Circumstances Exception if needed to adjust performance categories for 2021, the ACR said.
The college will continue its review of the proposed rule and will submit comments to CMS by the deadline of September 13, it said.
