The Medicare Physician Fee Schedule (MPFS) Final Rule for 2022 contained a 3.71% decrease in the Conversion Factor (CF), as we reported in our recent review of the rule. However, after lobbying by physicians and their representative organizations, Congress passed the Protecting Medicare and American Farmers from Sequester Cuts Act (the Act) that rolls back most of that cut and boosts the fee schedule that was contained in the MPFS Final Rule by 3%. We calculate that the CF for 2022 will therefore be $34.6062 instead of $33.5983, although the exact figure has not yet been released.
In addition to the CF reduction, two other factors were going to hit provider reimbursements next year. First, the sequester of 2% of Medicare payments to providers that had been in place since 2011 was suspended in 2020 and 2021 to provide support to providers during the COVID-19 public health emergency. It was set to begin again in 2022, but the Act pushed resumption of the sequester back a bit. It will start at 1% for the period April 1 – June 30, 2022, and then return to 2% from July 1 onward. The reduced sequester will be made up in 2030 through increases to 2.25% then 3.00% for portions of that year.
In addition, the Pay-As-You-Go Act of 2010, known as PAYGO, was to have implemented a 4% sequester on Medicare payments beginning in 2022. The Act pushed any PAYGO sequestration off until at least 2023, although the amount that will be needed under the PAYGO law could change as a result of the delay.
The net result of all this is as follows:
|
Effective 2021 |
Scheduled 2022 |
Final 2022 |
Final 2022 vs. 2021 |
Conversion Factor |
$34.8931 |
$33.5983 |
$34.6062* |
-0.82%* |
Payment Sequester |
|
|
|
|
January – March |
0% |
2% |
0% |
No change |
April – June |
0% |
2% |
1% |
-1.0% |
July – December |
0% |
2% |
2% |
-2.0% |
PAYGO Sequester |
0% |
4% |
0% |
No change |
The actual impact to radiology will depend on the modality and procedure mix of the individual practice. We will be analyzing the Act’s impact on the MPFS and will report our results. Subscribe to this blog for all the latest information that will help your practice optimize its revenue.
Sandy Coffta is the Vice President of Client Services at Healthcare Administrative Partners.
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