CMS Releases 2022 Final Rule for Services Reimbursed Under the MPFS
On November 2, 2021, the Centers for Medicare and Medicaid Services (CMS) released the calendar year (CY) 2022 Final Rule for services reimbursed under the Medicare Physician Fee Schedule (MPFS). This rule does apply to outpatient physical, occupational and speech therapy services provided in all outpatient therapy settings except a critical access hospital. This proposed rule only applies to traditional Medicare and not Medicare Advantage plans.
Highlights of the final rule include, but are not limited to, the following:
- Adding CPT codes billed by physical therapists to the Medicare telehealth services list
- Revised time frame for inclusion of CPT codes added to the Medicare telehealth services list on a temporary, Category 3 basis
- Supervision requirements of a physical therapist assistant or occupational therapy assistant in the private practice setting
- Remote Therapeutic Monitoring and the ability for Physical and Occupational Therapists to bill and be reimbursed for these codes in 2022
- Calculation of 15% payment reduction when CQ/CO modifier is appended to a CPT code
- CO and CQ Assistant Modifier Application Examples
- 2022 Medicare Annual Therapy Dollar Threshold Amount
- 2022 Conversion Factor that impacts payment for each CPT code
- MIPS 2022 Performance Threshold
- MIPS 2022 Exceptional Performance Threshold
- MIPS 2022 Data Completeness
- CMS Web Interface
- Removing the 3-point floor for each measure that can be reliably scored against a benchmark for the 2022 performance period
- MIPS Performance Category Redistribution Policies for Small Practice for the CY 2022 Performance Period
- MIPS High Priority Measure Bonus Points
- PT/OT Specialty Set Updates
- Class 1, 2 and 3 Quality Measures and Scoring Minimums for Each Class
- Class 4 Measure (New Class)
- Examples of Payment Reductions in 2022 Compared to 2021
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Based on the final rule, I will provide you with the 2022 payment rates per unit for some of the more common CPT codes billed by physical therapists, occupational therapists and speech-language pathologists. If Congress passes legislation changing the Conversion Factor, the payment amount for each CPT code for 2022 will also change. For my examples, I used Detroit, Michigan as the payment locality.
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In reviewing the final rule, did the proposed change to when the CQ/CO modifiers are applied become final?
Yes
What is Medicare’s definition of “via 2-way real-time audio-visual communication” for PT’s supervising PTA’s? Is it simply being available by cell phone? Or does it require a secured video conference platform?
Has to have audio and visual capability. Think IPhone.
Good Morning
Has the deductible been set yet?
Thank you
Not yet. Projected to be $217.00
In a hospital setting for out pt services we don’t ill under a physician but hospital NPI, does this mean we cannot use the CPTs enlisted for teletherapy (category 3)?
Can we use RTMs?
Once the PHE is declared over, telehealth will no longer be covered for outpatient PT, OT or SLP unless provided incident-to a physician and billed under the physicians NPI on a 1500-claim form.
Will Medicaid implement the therapy assistant payment differential across the board or will it vary by state?
Vary state-by-state whether Medicaid will or will not adopt the 15% payment reduction.
Have you seen any commercial payers adopt to the assistant payment reduction? Or do you predict any will?
Yes! TRICARE, Humana and UHC
We are an rehabilitation agency. We bill medicare on a UB form. Has anything changed regarding MIPS and it being available for clinics that bill as a rehab agency and with a UB form vs 1500 form?
No changes
Hi Rick, thanks for all the great content. I just need to clarify the coverage of telehealth for PT/OT in private practice.
Without working incident to a physician/NNP will a PT/OT in private practice will still be able to provide telehealth services until CY 2023?
Thanks
Once the PHE is over, no.