SCAI Highlights Issues in CMS’ Proposed 2022 Physician Fee Schedule

July 14, 2021—The Society for Cardiovascular Angiography & Interventions (SCAI) announced that the Centers of Medicare and Medicaid (CMS) released the Proposed Rule on the Physician Fee Schedule for the calendar year 2022. The CMS Fact Sheet for the proposed rule is available online here.

SCAI noted several topics that the society’s staff will be reading and drafting comments on in the coming weeks including conversion factor, practice expense, national coverage determination (NCD), cardiology rehabilitation and emergency medicine (E/M) telehealth services, fractional flow reserve derived from CT (FFRCT), and quality programs.

Additional analysis and commentary will be provided by SCAI soon. Questions may be addressed to Debra Mariani, SCAI’s Director, Regulatory Affairs at dmariani@scai.org.

In the announcement, the SCAI highlighted these topics as follows:

• Conversion Factor for CY 2022 will be 33.58. The Consolidate Appropriations Act approved a 3.75% payment increase for 2021 that will expire at the end of the year. As a result of this anticipated 3.75 decrease for 2022, there will also be the usual budget neutrality adjustment that will be a decrease of $1.31. It is estimated that the whole of Cardiology will have a combined impact of -2%. This will mean that the conversion factor will affect practices in different ways. Staff will be looking this over to provide more information.
• CMS is seeking comments on the practice expense for new CPT codes. CMS agreed with the Relative Value Scale Update Committee (RUC) recommendations for new CPT codes for Percutaneous Cerebral Embolic Protection and Exclusion of Left Atrial Appendage that go into effect on January 1, 2022. 
• CMS recommended values for Endovascular Repair of Aortic Coarctation and Cardiac Catheterizations for Congenital Defect CPT codes that are lower than the RUC recommended values. Staff will be reviewing the logic and drafting comments on these values.
• CMS is soliciting comments on the removal of the NCD for myocardial positron emission tomography. When the NCD is removed then payment is not automatic. The decision of payment is left to each local Medicare Administrator Contractor.
• On cardiology rehabilitation and E/M telehealth services, CMS is seeking comments on what telehealth services should be extended after the end of 2021 (ie, presumably the end of the public health emergency). SCAI will need to seek input from its members on these services to see if it wants to extend them after the year-end for 2021. SCAI may also want to comment on Inpatient, Observation Care, Office/Outpatient services, Critical Care Services, and the G codes for Cardiac Rehabilitation.
• For FFRCT, CMS is seeking comment on whether other codes would provide a more appropriate crosswalk in terms of resource costs (ie, a code of similar time and intensity). CMS is also more broadly soliciting public comment to help better understand the resource costs for services involving the use of innovative technologies, including but not limited to software algorithms and artificial intelligence.
• SCAI staff will be reviewing quality programs, such as MIPS (merit-based incentive payment systems), ACO (accountable care organizations), and AUC (area under the curve). CMS will provide clarifications and proposals around the scope of the AUC program pertaining to updates or modifications to orders and CMS is proposing a flexible effective date for AUC program claims processing edits and payment penalty phase to being the later of January 1, 2023, or the January 1 of the year after the year in which the Public Health Emergency for COVID-19 ends.