Medicare's 2022 Proposed Rule Release

Yesterday afternoon, CMS released the 2022 Physician Fee Schedule proposed rule.

This is an unusually significant rule in ways that won’t necessarily be obvious right away.

First, CMS has proposed adjusting clinical labor direct costs in such a way that redistributes RVUs between most specialties and practices. The consequences of that will be that specialties reliant on medical supplies and equipment will experience decreased rates, and others will experience increases.

Second, CMS has solicited input into the broad AI reimbursement debate that will become increasingly important over time. MCDA won’t comment on all of that right now (we're still working on our report on all that), but there, needless to say, are intricate policy issues that need to be drafted, debated, and figured out.

Third, CMS appears to be exerting its independence – which we fully support – to vet recommendations for other significant stakeholders (such as the RUC) and make modifications as they see appropriate. CMS has been doing this increasingly over most of the last decade, but they seem to be actualizing the approach more recently. This is a healthy thing for the Medicare program but will change the policy negotiation dynamic in very significant ways.

This rule touches far more in it than listed above, for which we are of course available for questions.

And finally, the last point for folks following the specifics, CMS regularly updates their files after errors are observed. We would recommend viewers download the most recent version of the Addendum B file that presents CMS’s proposed RVUs, as that has been corrected at least twice today following issues pointed out by MCDA to CMS.

James (

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