Three important takeaways from the 2022 Medicare Physician Fee Schedule Final Rule

2022 Fee Schedule

2,414. That’s the impressive number of pages in the 2022 Medicare Physician Fee Schedule Final Rule published on November 2, 2021. In this article, we’ll provide a summary of what’s new for telehealth, remote therapeutic monitoring (RTM), and care management services.

Telehealth: Coverage of audio-only services for mental health will be permanent.

The most important telehealth-related change pertains to audio-only codes for mental health services. While the Centers for Medicare & Medicaid Services (CMS) declined to add audio-only telephone evaluation and management (E/M) codes 99441-99443 to its permanent list of covered services, it did add audio-only mental health services, including audio-only telehealth for the treatment of substance abuse disorders.

However, there are some important caveats. First, the provider rendering the audio-only mental health service must have the technical capability at the time of the service to use an interactive telecommunications system that includes video. In addition, the beneficiary must choose audio-only (or be incapable of choosing). The beneficiary must also be located in their home at the time the service is delivered. (Note: New place of service [POS] code10 takes effect April 4, 2022 to denote telehealth provided in the patient’s home.) Providers must document the reason for using audio-only and append the appropriate service-level modifier.

Remember: Compliant billing is paramount. Interestingly, the Department of Justice recently announced criminal charges against more than 43 criminal defendants for their alleged participation in fraud schemes using telemedicine. The schemes resulted in more than $1.1 billion in false and fraudulent claims. Most providers don’t intentionally commit fraud; however, many may unknowingly submit inaccurate claims because they don’t understand the rules and regulations. Now is the time to consider performing an internal audit or hiring an external auditor to validate coding and documentation integrity.

RTM: New codes permit providers to bill for tracking certain non-physiological data.

CMS finalized five new RTM codes providers can bill when they monitor respiratory system status, musculoskeletal system status, therapy adherence, and therapy response. These codes (CPT codes 98975-98977 and 98980-98981) are for the initial set up of the device used to collect the RTM data, patient education on how to use the device, 30-day data transmission, and monitoring/treatment management services. Note that the devices used to collect RTM data must meet the FDA definition of a medical device described in section 201(h) of the Federal Food, Drug, and Cosmetic Act (FFDCA).

Care management services: CMS expands code sets, increases reimbursement.

As of January 1, 2022, physicians and non-physicians providers can report new CPT code 99437 when they spend more than 30 minutes providing chronic care management (CCM) services. There are also new codes for principal care management (PCM): CPT code 99426 (initial 30 minutes of clinical staff time) that replaces G2065 and CPT code 99424 (initial 30 minutes of physician or non-physician practitioner time) that replaces G2064. CMS also created two entirely new PCM codes: 99427 (subsequent 30 minutes of clinical staff time) and 99425 (subsequent 30 minutes of physician or non-physician practitioner time). With the exception of CPT code 99424, providers will see a fairly significant increase in reimbursement for care management services in 2022, making now the perfect time to re-evaluate the opportunity to provide these services that can improve patient outcomes.

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