Calendar Year (CY) 2022 Medicare Physician Fee Schedule Proposed Rule
On July 13, 2021 the Centers for Medicare and Medicaid Services (CMS) released the 2022 Medicare Physician Fee Schedule (MPFS) Proposed Rule. In this rule, CMS describes changes to payment provisions effective January 1, 2022.
Conversion factor
CMS estimates a CY 2022 conversion factor of $33.58, which is a decrease of $1.31 from the CY 2021 PFS conversion factor of $34.89.
| 2016 | 2017 | 2018 | 2019 | 2020 | 2021 (Proposed) | 2021 (Proposed) | 2022 (Proposed) |
|---|---|---|---|---|---|---|---|
| $35.8043 | $35.8887 | $35.9996 | $36.0391 | $36.0896 | $32.41 | $34.89 | $33.58 |
- The proposed budget neutrality adjustment to account for changes in relative value units (RVUs) and expiration of the 3.75 percent payment increase provided by the Consolidated Appropriations Act, 2021 lead to the decrease.
- Reimbursement for vascular ultrasound codes is holding steady.
- If Congress does not intervene, vascular surgery could see drastic cuts!
Changes to Direct Practice Expense (PE) inputs
- Market-Based Supply and Equipment pricing update
- The vascular ultrasound room (EL016) will increase from $475,332.88 to $479,753.32 in 2022, which is the fourth and final year of the phased-in pricing structure for medical supplies and equipment.
- Clinical Labor pricing update
- With the end of the pricing transition for medical supplies and equipment, CMS is focusing on updating the third component of PE — clinical labor staff wages. Clinical labor rates have not been updated since 2002. In the proposed rule, CMS explains that it will primarily use the 2019 Bureau of Labor Statistics (BLS) data to update these prices, supplementing with data from the Salary Expert, when BLS data is not available. For some clinical staff types, such as vascular technologist, where a direct comparison was not available, CMS proposed crosswalks to update the pricing.
- CMS proposed increasing the rate per minute for Vascular Technologists (L054A) from $0.54 to $1.07.
Noninvasive Vascular Lab Codes Proposed Rates
| CPT/ HCPCS | Mod | Description | Non-Facility PE RVUs2 | Mal-Practice RVUs2 | Total Non-Facility RVUs2 | CY22 PFS payment rate (Using CF $33.58) |
|---|---|---|---|---|---|---|
| 93880 | TC | Extracranial bilat study | 4.68 | 0.03 | 4.71 | $ 158.16 |
| 93882 | TC | Extracranial uni/ltd study | 3.11 | 0.02 | 3.13 | $ 105.11 |
| 93886 | TC | Intracranial complete study | 6.73 | 0.04 | 6.77 | $ 227.34 |
| 93888 | TC | Intracranial limited study | 4.14 | 0.03 | 4.17 | $ 140.03 |
| 93890 | TC | Tcd vasoreactivity study | 6.76 | 0.04 | 6.80 | $ 228.34 |
| 93892 | TC | Tcd emboli detect w/o inj | 7.71 | 0.04 | 7.75 | $ 260.25 |
| 93893 | TC | Tcd emboli detect w/inj | 9.75 | 0.04 | 9.79 | $ 328.75 |
| 93922 | TC | Upr/l xtremity art 2 levels | 2.24 | 0.02 | 2.26 | $ 75.89 |
| 93923 | TC | Upr/lxtr art stdy 3+ lvls | 3.38 | 0.03 | 3.41 | $ 114.51 |
| 93924 | TC | Lwr xtr vasc stdy bilat | 4.18 | 0.04 | 4.22 | $ 141.71 |
| 93925 | TC | Lower extremity study | 6.23 | 0.06 | 6.29 | $ 211.22 |
| 93926 | TC | Lower extremity study | 3.72 | 0.03 | 3.75 | $ 125.93 |
| 93930 | TC | Upper extremity study | 4.88 | 0.04 | 4.92 | $ 165.21 |
| 93931 | TC | Upper extremity study | 3.15 | 0.03 | 3.18 | $ 106.78 |
| 93970 | TC | Extremity study | 4.74 | 0.04 | 4.78 | $ 160.51 |
| 93971 | TC | Extremity study | 3.01 | 0.02 | 3.03 | $ 101.75 |
| 93975 | TC | Vascular study | 6.44 | 0.06 | 6.50 | $ 218.27 |
| 93976 | TC | Vascular study | 3.71 | 0.03 | 3.74 | $ 125.59 |
| 93978 | TC | Vascular study | 4.41 | 0.04 | 4.45 | $ 149.43 |
| 93979 | TC | Vascular study | 2.93 | 0.03 | 2.96 | $ 99.40 |
| 93980 | TC | Penile vascular study | 1.70 | 0.02 | 1.72 | $ 57.76 |
| 93981 | TC | Penile vascular study | 1.46 | 0.01 | 1.47 | $ 49.36 |
| 93985 | TC | Dup-scan hemo compl bi std | 6.55 | 0.06 | 6.61 | $ 221.96 |
| 93986 | TC | Dup-scan hemo compl uni std | 3.88 | 0.03 | 3.91 | $ 131.30 |
| 93990 | TC | Doppler flow testing | 3.79 | 0.03 | 3.82 | $ 128.28 |
| 76706 | TC | Us abdl aorta screen aaa | 2.40 | 0.01 | 2.41 | $ 80.93 |
CY 2022 Hospital Outpatient Prospective Payment System Proposed Rule
On July 19, 2021 the Centers for Medicare and Medicaid Services (CMS) released the calendar year (CY) 2020 Hospital Outpatient Prospective Payment System (HOPPS) Proposed Rule. This rule provides for a 60-day comment period ending on September 19, 2021. The finalized changes will appear in the final rule in early November and are effective January 1, 2022.CY 2022 Hospital Outpatient Prospective Payment System Proposed Rule
Imaging Ambulatory Payment Classification (APC)
The Centers for Medicare and Medicaid Services (CMS) does not propose any changes to the APC structure for imaging codes. The majority of vascular lab codes fall in these 2 APCs:
| APC | Group Title | CY 2021 Final Payment Rate | CY 2022 Proposed Payment Rate |
|---|---|---|---|
| 5522 | Level 2 Imaging without Contrast | $108.97 | $111.73 |
| 5523 | Level 3 Imaging without Contrast | $230.13 | $236.14 |
- The HOPPS payment rates for APC 5522 and APC 5523 are higher compared to the values included in the 2021 HOPPS Final Rule.
- The 2022 HOPPS Proposed Rule contains a payment rate of $111.73 for APC 5522, which represents an increase of 2.5% over the 2021 HOPPS Final Rule payment rate.
- The 2022 HOPPS Proposed Rule contains a payment rate of $236.14 for APC 5523, which represents an increase of 2.6% over the 2021 HOPPS Final Rule payment rate.