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The Medicare Physician Fee Schedule Proposal – What You Need to Know

September 16, 2021

Medicare Fee ScheduleThe Medicare Physician Fee Schedule proposed rule recently came out, and physician groups and individual providers are already calling it a “mixed bag” for practices. While the proposed rule definitely has some good policies in it, there are some concerning ones, too. It’s important to be informed on the coming proposed changes and make your voice heard if your practice has concerns.

To help you better understand what may be coming in 2022, we’ve put together a closer look at the proposal and some of the key points you need to know. From the great changes to the ones that seem most concerning, it’s important that you’re familiar with some of the key things proposed for 2022.

Proposed 3.75 Percent Conversion Factor Reduction

One of the biggest concerns that many practices and practitioners have is the proposed 3.75 percent conversion factor reduction, put in place due to current budget neutrality requirements. To avert this cut, there must be congressional intervention, so it’s currently unknown what will happen.

If this proposed reduction does go through, then the 2022 conversion factor would end up being $33.58, which is more than a dollar lower than the 2021 conversion factor – something that’s very concerning for many practices. The reason for this reduction is because the 3.75 rate increase that came last year with the coronavirus-related legislation will be expiring.

The Surgical Care Coalition noted that since this new proposed conversion factor isn’t keeping up with inflation, it may prove harmful to some specialists. Ultimately, this has a negative impact on patient care and may threaten patient access to essential procedures and treatments.

Shared Savings Program Changes

Significant changes to the accountable care organization (ACO) program were also included in the new Physician Fee Schedule proposed rule. One of the big changes that are proposed is a transition to new electronic quality reporting requirements that’s longer. These electronic quality reporting requirements were finalized in 2020 while the COVID-19 pandemic was going on, and postponing the start of these requirements was a good move.

Some practices and providers were worried about handling the new requirements, and the National Association of ACOs noted that they thought this delay in the changes was the correct thing to do.

Expanding Telehealth Reimbursement

One change that most physician groups are optimistic about is CMS’ proposal to expand telehealth reimbursement for some services with the new Physician Fee Schedule in 2022. Many physician groups have been calling for the expansion of audio-only mental health services and additional services, and they find this proposal encouraging.

The new proposed role is mainly focused on expanding telehealth reimbursement for behavioral and mental services. There’s also the idea of allowing some services added to the Medicare telehealth list during COVID-19 to stay there, at minimum until 2023.

Most industry groups are also happy that CMS has proposed postponement of the punitive phase of the new Appropriate Use Criteria program. At this point, it’s expected to be postponed until after the expiration of the COVID-19 public health emergency. Originally, the program was launched in 2020 and would penalize clinicians ordering advanced imaging if they hadn’t consulted with a Clinical Decision Support Mechanism. This would have gone into effect at the beginning of 2022, but will now be postponed.

Currently, CMS continues to accept comments on this new proposed rule until September 13, 2021. This is your chance to make your voice heard.

At, we work to help your practice navigate the ever-changing physician fee schedules, CPS changes, and other billing and coding changes that are essential to boosting your revenue cycle. Our professionals stay up-to-date on the latest changes and work with practices to handle their billing, coding, credentialing, and additional needs. If you’re looking for ways to improve your bottom line, contact today to learn how we can work together to help you.


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