The Centers for Medicare & Medicaid Services (CMS) released the proposed 2022 Physician Fee Schedule on Tuesday. In addition to proposed payment rates for Medicare next year, the agency included policy proposals to address health equity and expand patient access to comprehensive care.
The proposed rule, which is scheduled to be published in the Federal Register on July 23, addresses disparities in care that became evident during the COVID-19 pandemic. It recommends expanding access to telehealth services and other telecommunications technologies for behavioral health care, enhances diabetes prevention programs, and aims to improve quality programs for Medicare beneficiaries.
“Over the past year, the public health emergency has highlighted the disparities in the U.S. health care system, while at the same time demonstrating the positive impact of innovative policies to reduce these disparities,” said CMS Administrator Chiquita Brooks-LaSure in an announcement. “CMS aims to take the lessons learned during this time and move forward toward a system where no patient is left out and everyone has access to comprehensive quality health services.”
The 1,747-page proposed rule outlines the following changes:
Telehealth: CMS proposes to implement recently enacted legislation that removes certain statutory restrictions to allow patients in any geographic location and in their homes access to telehealth services for diagnosis, evaluation, and treatment of mental health disorders. In addition, the agency plans to expand access to mental health services for rural and vulnerable populations by allowing, for the first time, Medicare to pay for mental health visits when they are provided by Rural Health Clinics and Federally Qualified Health Centers to include visits furnished through interactive telecommunications technology. This proposal would expand access to Medicare beneficiaries, especially those living in rural and other underserved areas.
Audio-only telephone calls: CMS wants to pay eligible practitioners when they provide certain mental and behavioral health services to patients via audio-only telephone calls from their home when certain conditions are met. This includes counseling and therapy services provided through opioid treatment programs. “The COVID-19 pandemic has put enormous strain on families and individuals, making access to behavioral health services more crucial than ever,” said Brooks-LaSure. “The changes we are proposing will enhance the availability of telehealth and similar options for behavioral health care to those in need, especially in traditionally underserved communities.”
Medicare diabetes prevention program: The agency wants to expand the reach of the Medicare Diabetes Prevention Program (MDPP), which aims to help people with Medicare with prediabetes from developing type 2 diabetes. The expanded model is implemented at the local level by MDPP suppliers, organizations who provide structured, coach-led sessions in community and health care settings using a Centers for Disease Control and Prevention approved curriculum to provide training in dietary change, increased physical activity, and weight loss strategies.
Approximately one in three American adults (over 88 million) have prediabetes, and more than eight in 10 do not even know they have it. Many are at risk for developing type 2 diabetes within five years. Several underserved communities—including African Americans, Hispanic/Latino Americans, American Indians, Pacific Islanders, and some Asian Americans—are at particularly high risk for type 2 diabetes.
During the COVID-19 public health emergency, CMS has been waiving the Medicare enrollment fee for new MDPP suppliers and has observed increased supplier enrollment. In the proposed rule, CMS intends to waive this fee for all organizations that apply to enroll in Medicare as an MDPP supplier on or after January 1, 2022. Additionally, CMS wants to make delivery of MDPP services more sustainable and to improve patient access by making it easier for local suppliers to participate and reach their communities by proposing to shorten the MDPP services period to one year instead of two years. This proposal, the agency said, would reduce the administrative burden and costs to suppliers. CMS also proposes to restructure payments so MDPP suppliers receive larger payments for participants who reach milestones for attendance and weight loss.
Health equity data collection: CMS also aims to address significant and persistent inequities in health outcomes in the U.S. by improving data collection to better measure and analyze disparities across programs and policies. In the proposed rule, CMS is soliciting feedback on the collection of data and on how the agency can advance health equity for people with Medicare (while protecting individual privacy), potentially through the creation of confidential reports that allow providers to look at patient impact through a variety of data points—including, but not limited to, LGBTQ+, race and ethnicity, dual-eligible beneficiaries, disability, and rural populations. Access to these data may enable a more comprehensive assessment of health equity and support initiatives to close the equity gap. In addition, hospitals and health care providers may be able to use the results from the disparity analyses to identify and develop strategies to promote health equity.
Quality Payment Program: CMS intends to improve the quality of care for people with Medicare through changes to the agency’s Quality Payment Program (QPP), a value-based payment program that promotes the delivery of high-value care by clinicians through a combination of financial incentives and disincentives. The agency proposes to require clinicians to meet a higher performance threshold to be eligible for incentives. This new threshold aligns with the requirements established for the QPP’s Merit-based Incentive Payment System (MIPS) under the Medicare Access and CHIP Reauthorization Act of 2015.
To ensure more meaningful participation for clinicians and improved outcomes for patients, CMS is moving forward with the next evolution of QPP and proposing its first set of measures and activities that address rheumatology, stroke care and prevention, heart disease, chronic disease management, lower extremity joint repair (e.g., knee replacement), emergency medicine, and anesthesia. CMS also wants to revise the current eligible clinician definition to include clinical social workers and certified nurse-midwives, as these professionals are often on the front lines serving communities with acute health care needs.
Payment provisions: By law, the fee schedule must be budget neutral. Although Congress did give physicians a 3.75 percent payment increase as part of the Consolidated Appropriations Act late last year, that increase expires after this year. CMS proposes to cut the conversion factor from $34.89 to $33.58. CMS said the adjustment is necessary to account for changes in relative value units and expenditures that would result from its proposed policies.
Comments about the proposed rule are due by Sept. 13.