Medicare Compliance & Reimbursement

The calendar year (CY) 2022 Medicare Physician Fee Schedule (MPFS) proposed rule covers a lot of policy ground and offers a few E/M surprises.

Here’s a quick overview of four key points to know:

1. E/M 2021 revisions: “For CY 2022, we are making several proposals that take into account the recent changes to E/M visit codes, as explained in the AMA CPT^® Codebook, which took effect January 1, 2021,” a Centers for Medicare & Medicaid Services (CMS) fact sheet indicates. “We are also proposing to clarify and refine policies that were reflected in certain manual provisions that were recently withdrawn.”

2. Split/Shared updates: CMS proposes to revise its policies on split/shared visits to address the changing role of nonphysician practitioners (NPPs) and “clarify conditions of payment,” the fact sheet mentions. The proposed changes would include fresh guidance on reporting and documentation; defining the split/shared E/M visit; creating a modifier for the service; and codifying the changes.

3. Critical care policies: The rule proposes to modify and refine E/M visit policies for critical care, including clarifying definitions and billing rules.

4. Teaching physicians services modifications: CMS proposes modifying the CY 2021 framework for residents in a teaching setting. The rule aims to “clarify that the time when the teaching physician was present can be included when determining E/M visit level,” the fact sheet says. “Under the primary care exception specifically, only MDM would be used to select the visit level to guard against the possibility of inappropriate coding that reflects residents’ inefficiencies rather than a measure of the time required to furnish the services,” CMS indicates.