11月19日,医疗保险中心 & 医疗补助服务(CMS) published its final rule regarding revisions to the Medicare Physician Fee Schedule (MPFS) for calendar year 2022. 最终规则中最值得注意的修改是:

  1. Reset of the physician fee schedule (PFS) and reduction of the conversion factor (CF)
  2. 扩大远程保健覆盖面
  3. 为高级实践提供者扩大实践范围(APP)

医生收费表和减少转换因素

The 《2021年综合拨款法案 申请临时增加PFS为3.75%. As of January 1, 2022, 这笔增加的付款将到期, 导致CF总额减少1美元.30和MPFS CF为CY 2022的33美元.59,从2021年第1期的多边货币方案成本为34美元.89(比2020年CY的CF减少了36美元.09). 基于此调整, 有医生的雇主建立了生产力模型, who do not adjust the compensation per work relative value unit (wRVU) rate for their physicians, may find that they will pay more in incremental compensation than they earn in incremental reimbursement under the 2022 MPFS. An issue compounded if an adjustment was not made in 2021 following the reweighting of wRVUs and reduction of the conversion factor. Work RVUs for Office/Outpatient evaluation and management services increased by a range of 7% to 13% for new patient visits and 28% to 46% for established visits under the 2021 MPFS. Increased wRVUs for the same work for many specialties will continue under the 2022 MPFS, and will impact compensation for those physicians paid on a per wRVU basis, 而报销费用则进一步下降.

There is some hope that physicians and organizations may receive another temporary reprieve. On December 10th 拜登总统签署了 保护医疗保险和美国农民免受自动减支法案的影响 into law. This bill eliminates sequestration in the first quarter of 2022 and reduces the impact from 2% to 1% in the second quarter, 它消除了现收现付的削减, 最重要的是,它规定了为期一年的3%的临时增长, 哪一个最能抵消3.75%临时,一年增加参考以上. Follow AAPCP 查阅有关法例的最新资料.

Telehealth Coverage

根据最终规则,CMS最终确定了 telehealth services list that was temporarily added during the COVID-19 Public Health Emergency. The services will remain on the list of approved telehealth services through December 31, 2023, while CMS evaluates whether the services should be permanently added to the Medicare telehealth services list. In addition, CMS has amended the definition of interactive telecommunications systems for the provision of telehealth services when treating mental health disorders. 以前,这被定义为允许使用多媒体设备 two-way,病人和医生之间的实时互动交流. 新的定义将允许通信设备包括 audio only technology for the diagnosis, evaluation, and/or treatment of mental health disorders.

高级实践提供者(APP)

Services and offerings from APPs continue to grow and evolve as APPs consistently help to address physician shortages 在医疗保健行业. Beginning January 1, 2022, CMS has 1) revised the definition of a Split (shared) E/M visit to incorporate E/M visits split (shared) by a physician and APP in the same practice, and 2) 批准直接支付给医生助理 个人根据医疗保险B部分提供的专业服务.

2022年医生补偿

There are several unprecedented external factors simultaneously affecting physician compensation at this time. COVID-19大流行影响了总体患者数量, 哪些影响了年度医生的wrv和收集. This, in connection with the MPFS changes in 2021 and 2022 have made it more difficult to determine appropriate physician compensation.

In order to best understand how an organization’s financial performance may be affected, organizations should assess the impact of these MPFS changes on both reimbursement and physician compensation. 采取积极主动的方法是很重要的. 即使3%的缓刑生效,也将于明年到期. 减少削减的年度立法努力可能并不总是出现. LBMC has been assisting our clients in determining the financial impact of the 2021 and 2022 MPFS changes to their particular organization. A number of our clients have chosen to remain on the 2020 MPFS to gain additional time to assess the impact, 做出适当的调整, and/or await relevant, 类似的调查数据.

One other key component in considering physician compensation is determining what compensation benchmark survey data is most appropriate for consideration going forward. 鉴于上述潜在问题, LBMC does not recommend the use of or reliance on the 2021 survey data (based on 2020 data) to establish and document fair market value as 2021 surveys include the impact of COVID-19 but exclude consideration of the 2021 and 2022 MPFS changes.

Complexities within the survey data require more expertise and analysis than in years past. It is more important than ever to consult with external advisors to 1) ensure consideration of all potential impacts from the 2021 and 2022 MPFS revisions, 2) determine the appropriate data to use and how to apply it and 3) reestablish internal and external processes for determining and documenting fair market value.

LBMC’s 医疗补偿估价 team combines an understanding of complex financial and regulatory matters with an ability to analyze voluminous financial operations information to deliver fair market value opinions to ensure maximum compliance. For more information, contact our team today.

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