Overview of the 2022 Physician Fee Schedule Final Rule

Overview of the 2022 Physician Fee Schedule Final Rule

In January, CMS released the 2022 Physician Fee Schedule Final Rule. This contains important information about how your care management services will be valued and reimbursed in 2022. The overview is dense – over 1,000 pages. But don’t worry! DocsInk has taken the time to identify key trends and changes that you need to know about. Not only did we make an abridged version….we made an abridged abridged version 🙂

To download DocsInk’s complete 2022 Physician Fee Schedule Final Rule – click here.

In the meantime, here’s short and skinny:

Finalized Conversion Factor

Centers for Medicare and Medicaid Services’ (CMS) 2022 conversion factor1 has been set at $34.60. 

What does this mean for your care management service? 
It depends on the type of care management service you provide:

Chronic Care Management (CCM): 

  • CMS has adopted the American Medical Association’s (AMA) RVU2 Update Committee’s (RUC) recommendation to increase RVU for CCM services to better reflect the value of time spent providing CCM services. 
  • As a result, the reimbursement for CCM services has increased in 2022.

Remote Physiologic Monitoring (RPM): 

  • There are minimal reimbursement rate adjustments to RPM services based on both slight reductions to RVUs and the conversion factor rate. 
  • Based on the conversion factor listed above, the decline in reimbursement will be marginal compared to 2021 rates. 

 Source for RVU definition: https://www.aapc.com/practice-management/rvus.aspx

Chronic Care Management 

  • CMS added 1 new CCM CPT code, 99437 , which is an add-on code to the existing 99491 code. They also updated a requirement of beneficiary consent. 

99437

Chronic care management  services, provided personally by physician or other qualified healthcare professional (QHP), each additional 30 minutes per calendar month with the following required elements: 

  1. Multiple (two or more) chronic conditions expected to last 12 months, or until the death of the patient.
  2. Chronic conditions place the patient at significant risk of death, acute exacerbation/decompensation, or functional decline.
  3. Comprehensive care plan established.

What is an add-on code?

Since 99437 is classified as an “add-on” code, it may only be billed in conjunction with CPT code 99491, and it follows the same billing requirements as 99491. 

  • One of these requirements is that the care management services must be performed personally by a physician or other qualified healthcare professional (QHP).

This is where a gray-area appears in the CMS Final Rule: 

  • In CMS’s final rule, CPT Code 99437 “describes CCM services furnished by clinical staff under the supervision of a physician or NPP who can bill E/M services and CCM services personally furnished by a physician or NPP.”
  • This is in direct contradiction to the AMA’s CPT codebook for 99437 CPT code, which specifies that the code can only be performed by a physician or QHP3.

So, what should I do? DocsInk recommends that you err on the side of caution, and only bill for 99437 when the care management service is performed by the physician for QPH in order to avoid being audited.

During the Public Health Emergency (PHE) CMS allows beneficiary consent to be obtained by auxiliary staff under general supervision, meaning the staff can be remote from the billing provider4. Previously, CMS required that beneficiary consent be obtained directly from the billing provider or by staff working directly under their supervision. 

Telehealth 

Category 3 Codes 

In 2021, CMS created a list of Category 35 codes to describe the telehealth visits which will be covered temporarily during the COVID-19 PHE. The 2022 Final Rule extends the reimbursement of the Category 3 telehealth codes throughout the last day of 20236, giving CMS time to evaluate which telehealth visit codes meet the requirement for permanent coverage beyond 2023.

Allowances for Geographic Restrictions and Originating Sites 

During the PHE, waivers were granted under section 1135 of the Social Security Act and the CARES Act, giving CMS the authority to waive geographic origination requirements for the duration of the PHE7. To continue these site allowances beyond the PHE, Congress must pass legislation to overturn section 1834(m) of the Social Security Act. 

There is an exception to the geographic restrictions beyond the PHE in regards to the provision of telehealth services in the home of an individual for the treatment, diagnosis, or evaluation of mental health or substance abuse disorder. 

Telemental Health Services

CMS finalized keeping Section 123 of the Consolidated Appropriations Act legislation, which removed geographic restrictions and allowed a patient’s home to be the originating site for telehealth visits when used for the purposes of diagnosis, evaluation, or treatment of a mental health disorder8

Conditions to Medicare reimbursement:

  •  Requires an in-person visit within six months of the initial telemental service.
  • An in-person visit must be conducted by the provider at least once every twelve months thereafter9.

Audio-Only Mental Health Services

CMS finalized reimbursement for audio-only telehealth services for the treatment of mental health conditions beyond the PHE. 

The following conditions must be met: 

  • The practitioner has the capability to use an interactive telecommunication10 system that includes video. 
  • The beneficiary is incapable of, or fails to consent to, the use of video technology 
  • The beneficiary is located at their home at the time the service is delivered11.
  • The practitioner documents the reason for using audio-only technology in the patient’s medical record, and they use the appropriate service level modifier. 

1Conversion Factor (CF): the number which is multiplied by the relative value units (RVUs) assigned to each CPT and HCPCS Level II code, which together determine the annual fee-for-service Medicare reimbursement rates.
2Relative Value Units (RVU): define the value of service or procedure relative to all services and procedures. The measure of value is based on the extent of work required from the physician, clinical and nonclinical resources, and expertise required to deliver the service to the patient.
3According to the American Medical Association (AMA) CPT Codebook, “Code 99437 is reported in conjunction with 99491 for each additional minimum of 30 minutes of physician or other qualified health professional time.”
4The PHE will be extended into 2022, however at this time it is for an indeterminate amount of time.
5Category 3 codes are a subset of codes that were added during the PHE, however not every temporary code added is considered a Category 3 code. Codes not considered Category 3 codes.
6Codes not considered category 3 will not be considered for reimbursement once the PHE ends.
7Prior to the PHE, in order to be reimbursed for telehealth visits, care had to be provided at an eligible site in a rural area.|
8A hotel, car, etc could be classified as “home” for those who are without homes.
9There is an exception: if the patient and practitioner consider the burdens of the visit to outweigh the benefits. The practitioner must document this on the patient’s medical record, then the in-person visit is not applicable for 12-months.


Who is DocsInk

DocsInk®, a NC-based healthcare technology company founded in 2012, addresses the fiscal, communication and connectivity needs of medical professionals. Utilizing Software-as-a-Service, DocsInk is revolutionizing the healthcare technology industry. Its simple solutions improve the speed, efficiency, accuracy and options in the delivery of patient care, and our team provides a customer experience second to none. With more than 15,000 users who serve more than one million patients across the United States, DocsInk is among the top healthcare communication companies. Learn more at www.docsink.com.

RPM – The Right Tool for COVID-19 and Beyond

RPM – The Right Tool for COVID-19 and Beyond

Remote physiologic monitoring (RPM) technology, also called remote patient monitoring, is playing a vital role during the current pandemic. It excels in connecting patients to care teams, providing real-time clinical data needed to control symptom and disease progression. As COVID-19 continues to spread, our country faces the unprecedented challenge of managing health in a safe and effective manner.

Time and resources are valuable commodities for all healthcare organizations — especially as medical professionals battle this pandemic. Clinicians adopt RPM to monitor, assess and address patients’ health, instantly receiving vitals and data from thermometers, pulse oximeters and blood pressure monitors. With real-time insights come fast response, better prioritization and triage of patients, and faster delivery of healthcare when every minute counts.

Patients no longer have to rely on their own discretion as to whether their rising temperature or shortness of breath warrant a visit to the nearest emergency room. With RPM technologies, they have confidence that they are being monitored; a change in their health status will be immediately conveyed to their care team. RPM expedites the delivery of medical care in a safe and virtual manner, as face-to-face treatment now poses too large of a risk potential in many cases. The Centers for Medicare and Medicaid Services (CMS) recently released new regulations covering these services for patients with acute conditions.

CPT Codes and RPM Adoption

The recent healthcare crisis put a spotlight on the value that tools like RPM and wearable devices in the management of patient outcomes. It was in 2019, however, that their use became more common. That is when CMS published several new RPM Current Procedural Terminology (CPT) codes. These CPT codes more clearly improve reimbursement for the work typically performed around RPM service programs. This includes issuing devices to the patient and training them on its use. It also supports electronic transmissions, monitoring clinical data, and interactively communicating with patients.

These newly released codes successfully boosted physician adoption. In Spyglass Consulting Group’s 2019 survey, 88% of healthcare providers reported either purchasing or evaluating RPM technologies. Providers have found RPM valuable in managing high-risk populations. It also led to expansion of chronic care management programs, aiding in the successful transition to value-based care models. RPM is highly effective in treating prevalent diseases, such as diabetes, congestive heart failure, hypertension, chronic obstructive pulmonary disease, and asthma. Studies demonstrate that they play a significant role in substantially reducing readmission rates and overall costs of care.

In 2020, CMS further relaxed their RPM guidelines. Clinical staff can now perform these services under the supervising physician’s general supervision based on CMS’ incident-to guidelines. This allows care providers to work efficiently, freeing up physician time for more complex treatments and procedures. It also expands the potential business models for RPM programs, as the physician doesn’t have to be in the same physical location while the services are performed. 

Medical Benefits of RPM

DocsInk uniquely positions medical professionals to successfully implement an RPM program. It simplifies the day to day use of remote patient monitoring for medical professionals by seamlessly connecting to any wearable device. Additionally, it offers customizable clinical alert notifications, facilitates templated patient surveys, streamlines interactive patient communications, and instantly bills for all professional services rendered.

We are all working to gain control over the global health crisis. Yet we must simultaneously navigate value-based care, manage chronically-ill patient populations, and provide general health coaching. That’s why we created a new solution. DocsInk’s RPM solution offers a strong ROI, improved workflow efficiencies, and the tools to achieve patient goals.

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5 Benefits of DocsInk’s Telehealth Solution

5 Benefits of DocsInk’s Telehealth Solution

Both medical professionals and patients alike greatly benefit from telemedicine services. For example, the adoption of communication based technology services (CBTS) is becoming widespread; Medicare, Medicaid and many private insurance payers have relaxed their administrative guidelines and improved their reimbursement models. FH Health Indicators reports that telemedicine visits grew 53% nationally from 2016 to 2017. Here are the top five reasons for clinicians to adopt DocsInk’s Telehealth Solution:

1. Better Access to Care

Making medical care more available is essential to achieving a healthy patient population. The Centers for Disease Control and Prevention reports that 46 million Americans, 15% of the U.S. population, live in rural areas. The nearest medical center is 20+ miles away. With restricted access to public transportation, DocsInk’s Telehealth Solution allows them to get the care they need when they need it. Patients are more likely to be compliant and engaged when they have easy access to prompt, quality medical treatment. In many rural areas, telemedicine provides direct access to specialists which would not otherwise be accessible by patients. In addition, the COVID-19 pandemic makes it every more critical for clinicians to reach patients at home.

2. Cost Effectiveness

As the healthcare industry continues to transition from fee-for-service to value-based care, it is critical to reduce expenses. Avoidable readmissions account for $17B  in expenses, and preventable emergency use represents $8.3B in costs each year. Both of these numbers may be reduced with improved patient/care team communication via telemedicine visits. Further prooft comes from the Veterans Administration, which reaped an annual savings of $6,500 per patient when using telemedicine services. Other studies have shown a 50% reduction in emergency room visits and 90% reduction in overall hospitalizations of chronically-ill patients. DocsInk’s Telehealth Solution allows for quality value-based care and reduction of readmission costs.

3. Improved Patient Outcomes

Convenience and access to care have proven to be key in maximizing patient engagement and compliance. DocsInk’s Telehealth Solution facilitates high-touch, efficient care options for patients who require frequent monitoring. Whether the impetus is prescription adherence, post-surgical care, chronic disease management or inpatient discharge instructions, this option delivers.

Johns Hopkins reported that medication nonadherence is one of the largest factors negatively impacting health outcomes. In short, these issues can be addressed with DocsInk’s Telehealth Solution, and is recommended the Health Information Technology Playbook

4. Boost Patient Satisfaction and Engagement

Patient satisfaction is a key indicator for measuring the quality of healthcare. Patient satisfaction scores help ensure optimal reimbursements and higher patient retention rates. But a satisfied patient is also more apt to be engaged in their overall health. 

Telemedicine has proven to increase patient satisfaction scores, and in turn, health outcomes. In a Massachusetts General Hospital study, 68% of patients rated their telemedicine visits a 9 or above on a 10 point scale. Their quality of care and convenience of access expectations were exceeded. Another study published in the Annals of Vascular Surgery shows that telemedicine may significantly improve a patient’s satisfaction with postoperative care — as well as their views on quality of life. DocsInk’s Telehealth Solution can help you stay on top of your patients overall quality of care satisfaction and in turn, their overall health outcome.

5. Improved Revenue

There are a number of ways that DocsInk’s Telehealth Solution impacts revenue. Because it’s convenient, virtual care can translate into fewer no-shows and cancellations. These cost practices a great deal of time and money, ranging from 3 – 14% of total clinic income. Telemedicine also facilitates a more efficient clinical schedule with increased billable time. Plus, it allows for the transition of non-paid patient phone calls into revenue generating visits and virtual check-ins.

Finally, DocsInk’s Telehealth Solution can substantially reduces overhead costs per visit, which then promotes improved staff productivity and time savings.

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