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July 15, 2021

CMS issues proposed CY2022 medicare physician fee schedule

Proposals include expanded access to telehealth, updates to CMS quality programs, and a continued focus on health equity and digital quality measurement

On July 13, the Centers for Medicare & Medicaid Services (CMS) issued their Calendar Year (CY) 2022 Medicare Physician Fee Schedule (MPFS) Proposed Rule. Among the key changes, CMS plans to allow providers to continue providing certain telehealth services added during the public health emergency (PHE) until the end of 2023, aiming to gather more information about how the flexibilities have affected patients and the program before determining if they should be made permanent. The rule also makes changes to the Quality Payment Program (QPP), including a proposal to sunset the traditional Merit-based Incentive Payment System (MIPS) by 2027 and shift towards implementation of MIPS Value Pathways (MVPs), aimed at connecting activities and measures relevant to a specialty, medical condition, or episode of care. The rule also proposes changes to the Medicare Diabetes Prevention Program (MDPP), aimed at boosting supplier enrollment and increasing beneficiary participation, among other priorities.

"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. "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." In addition to incorporating health equity throughout the rule's proposals, CMS seeks specific feedback on the collection of health equity data to enable a more comprehensive assessment of health equity and support initiatives to close the equity gap. CMS also requests information on CMS's transition to digital quality measurement in CMS quality reporting and value-based purchasing programs by 2025, along with a variety of other requests for comment. Comments are due September 13, 2021.

The proposed rule sets the CY 2022 PFS conversion factor at $33.58, a decrease of $1.31 from the CY 2021 PFS conversion factor of $34.89. The change is driven by a required budget neutrality adjustment and expiration of the 3.75% payment increase provided for CY 2021 by the Consolidated Appropriations Act of 2021 (CAA). CMS also notes that it is engaged in an ongoing review of payment for Evaluation and Management (E/M) visit code sets and proposed a number of refinements to current policies for split (or shared) E/M visits, critical care services, and services furnished by teaching physicians involving residents.

Additional information is available in the attached Tax Alert.


Contact Information
For additional information concerning this Alert, please contact:
Washington Council Ernst & Young
   • Heather Meade (
   • Laura Dillon (


CY2022 medicare physician fee schedule