The Final Rule for 2022: What’s New and How Changes in the Medicare Physician Fee Schedule and Quality Payment Program Affect Dermatologists
The Centers for Medicare & Medicaid Services (CMS) 2022 final rule, which went into effect on January 1, 2022, contains updates affecting the practice of dermatology. This article reviews many of the changes to the Medicare Physician Fee Schedule (PFS) and Quality Payment Program (QPP) and their impact on clinical practice.
Practice Points
- The Centers for Medicare & Medicaid Services (CMS) 2022 final rule contains multiple updates affecting the practice of dermatology.
- Adjustments to the conversion factor and legislative-level actions have led to changes in reimbursement for many procedures within dermatology and beyond.
- Other notable updates include refining the definition of split evaluation and management visits, clinical labor pricing, and billing for physician assistant services.
- Changes in the Merit-Based Incentive Payment System (MIPS), cost measures, and MIPS value pathways also will impact many dermatology practices.
QPP Updates
Several changes were made to the Merit-Based Incentive Payment System (MIPS). Some of these changes include:
- Increase the MIPS performance threshold to 75 points from 60 points.
- Set the performance threshold at 89 points.
- Reduce the quality performance category weight from 40% to 30% of the final MIPS score.
- Increase the cost performance category weight from 20% to 30% of the final MIPS score.
- The extreme and uncontrollable circumstances application also has been extended to the end of 2022, allowing those remarkably impacted by the COVID-19 public health emergency to request for reweighting on any or all MIPS performance categories.
Cost Measures and MIPS Value Pathways
The melanoma resection cost measure will be implemented in 2022, representing the first dermatology cost measure, which will include the cost to Medicare over a 1-year period for all patient care for the excision of a melanoma. Although cost measures will be part of the MIPS value pathways (MVPs) reporting, dermatology currently is not part of the MVP; however, with the CMS moving forward with an initial set of MVPs that physicians can voluntarily report on in 2023, there is a possibility that dermatology will be asked to be part of the program in the future.10
Final Thoughts
There are many upcoming changes as part of the 2022 final rule, including to the conversion factor, E/M split visits, PA billing, and the QPP. Advocacy in these areas to the CMS and lawmakers, either directly or through dermatologic and other medical societies, is critical to help influence eventual recommendations.
