On September 13, 2021, AAPM&R submitted comments to the Centers for Medicare and Medicaid Services (CMS) in response to the Medicare Physician Fee Schedule Proposed Rule.  This comprehensive letter addresses proposals for 2022 which could significantly impact physiatry.  For detailed information about the proposed rule, including proposed payment rates for physiatric services, please visit the Academy website. 

Academy comments address many issues including:

• Conversion Factor – Medicare has proposed a reduction in the Conversion Factor from $34.89 to $33.58.  A large portion of this reduction is due to the expiration of the 3.75% one-year update Congress provided for 2021.  AAPM&R urges CMS to work with Congress on long term solutions for providing positive updates to the Conversion Factor every year.
• Telehealth – AAPM&R encourages Medicare to continue flexibilities created under the public health emergency through end of year 2023.  Further, AAPM&R urges CMS to continue coverage for telephone visits.
• Separate Payment for Chronic Pain Management – AAPM&R supports creating separate coding and payment for chronic pain management services.
• Appropriate Use Criteria (AUC) – AAPM&R urges CMS to delay the penalty phase of the AUC program.
• PASC Rehabilitation – AAPM&R supports proposal to add COVID-19 as a covered condition for pulmonary rehabilitation.
• Quality Payment Program – AAPM&R urges CMS to reconsider the proposal to phase out the MIPS program in favor of the MIPS Value Pathway program by 2028.  Further, your Academy makes several recommendations regarding ongoing flexibilities for MIPS reporting in response to the public health emergency.

A final rule addressing these and many other proposals is expected in November.  Policies finalized in that rule will take effect January 1, 2022, unless otherwise specified.  Your Academy will continue to monitor CMS proposals and share relevant updates via the Academy website.