CMA comments on the 2022 proposed Medicare Physician Fee Schedule

September 14, 2021

The Centers for Medicare and Medicaid Services (CMS) recently released the 2022 Medicare Physician Fee Schedule and Quality Payment Program (QPP) proposed rule. This rule includes updates to payment rates for physicians and other health care professionals, expands the use of telehealth, continues evaluation and management (E/M) policies from 2021, proposes new policies for the 2022 performance year of the QPP, and includes many other provisions. The California Medical Association (CMA) recently submitted comments on the proposed rule.

In what amounts to a “perfect storm” of payment reductions going into effect on January 1, 2022, physician practices face Medicare cuts on multiple fronts that amount to a combined 9.75% cut. This would directly impact Medicare patients’ ability to access care. And all of this comes at a time when physician practices are still recovering from the exhaustion and financial instability of the COVID-19 public health emergency.

While not all of the cuts are under CMS jurisdiction, CMA is urging CMS to stop the 3.75% budget neutrality cuts that do fall under the agency’s purview, and to reduce the QPP reporting burdens.

“CMA appreciates CMS’ overall commitment to improving patient access to high-quality physician services and helping physicians participate in innovative value-based care models, including the on-going use of telehealth. However, we are extremely concerned with the growing financial instability of physician practices caused by Medicare payment policies, the burdensome and clinically irrelevant Quality Payment Program requirements that change every year, as well as the profound exhaustion and severe revenue reductions imposed by the COVID-19 pandemic,” said CMA President Peter N. Bretan, Jr., M.D., in the comments. “The 9.75%+ physician payment cuts slated for January 1, 2022, including the 3.75% cuts due to budget neutrality, are unconscionable given the sacrifices physicians have made during the COVID-19 Public Health Emergency.”

At least 6.75% of the 9.75% payment cut will need to be stopped by Congress. CMA, the American Medical Association and others in organized medicine have started a grassroots campaign urging Congress to stop those cuts.

Telehealth and Audio-Only Expansion

The proposed payment rule would extend telehealth coverage through the end of 2023 for all services added to the Medicare telehealth services list in response to the COVID-19 public health emergency. CMA strongly supports this proposal, but is also asking that the CPT codes for telephone E/M services (99441-99443) be included. The CMS proposal would also implement permanent telehealth coverage for mental health care services, as recently enacted by Congress. CMA strongly supports the CMS proposal to expand the telehealth definition to include audio-only communication for mental health services.

CMS has also indicated its support for making permanent the telehealth waivers Congress issued during the public health emergency addressing payment parity, originating site and geographic site. CMA is urging CMS to continue to reimburse telehealth services at parity with in-person services after the public health emergency concludes, including audio-only services for fee-for-service and Medicare Advantage.

Quality Payment Program

CMA is urging CMS to significantly reduce the unnecessary burdens in the QPP program, including to extend the Extreme and Uncontrollable Circumstances Exception to the MIPS program for physicians in 2022 and to reduce the weight of the cost category, which is proposed to be 30% for 2022. “To hold physicians to such a difficult cost threshold during a health care pandemic is completely unreasonable,” said Dr. Bretan. “It will continue to discourage physicians from treating sicker patients.” 

Evaluation and Management

CMA is asking CMS to update the values for post-operative evaluation and management (E/M) office visits in the global surgical codes just as CMS updated the values for the stand-alone E/M visits.  

Alternative Payment Models

CMA in its comments urged CMS to authorize more physician-led alternative payment model options for physicians and ones that do not initially require physicians to accept downside financial risk.  CMA also urged CMS to make changes to the Accountable Care Organization program so that high-performing physicians may see more in shared savings.

E-Prescribing for Controlled Stances

The proposed payment rule would delay the requirement for physicians to electronically prescribe controlled substances from January 1, 2022, to January 1, 2023. CMA strongly supports this delay.

Appropriate Use Criteria

CMS is proposing to delay the penalty phase of the Appropriate Use Criteria (AUC) program for imaging services until January 1, 2023, or the January following the end of the public health emergency, whichever is later. CMA strongly supports this delay.


CMA is asking CMS to immediately implement CPT code 99072 with no patient cost-sharing during the public health emergency.  This code describes the extra supplies and clinical staff time required to perform COVID-19 safety protocols.  It will help to address the significant financial pressures placed on physicians by the COVID-19 pandemic.

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