Key updates in 2022 may affect documentation, coding, billing and reimbursement for many practices. This year, rheumatology practices should prepare for important revisions with regard to evaluation and management (E/M) and split/shared billing policies, as well as new guidelines and policies for telehealth services.
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Medicare Physician Fee Schedule Changes
The Centers for Medicare & Medicaid Services (CMS) was set to lower the 2022 conversion factor (i.e., the amount Medicare pays per relative value unit [RVU]) from $34.89 to $33.59, but in response to advocacy from the ACR and other provider and patient groups, Congress intervened in December with a one-year rate increase of 3%. The 2022 conversion factor is now $34.6062, nearly the same as in 2021.
Office & Other Outpatient E/M Services
In 2021, the Current Procedural Terminology (CPT) code set made substantial changes to the new and established patient E/M codes (99202–99215). For 2022, the CPT has clarified several aspects of those changes, including:
- Defining specific activities that don’t count when time is used to determine the level of service: Travel, teaching that is general and not limited to management of a specific patient, and time spent on other, separately reported services.
- Clarifying when to report a test that is considered but not selected after shared decision making: A test that is considered but not performed counts if the consideration is documented in the patient’s medical record. For example, the physician may explain to the patient that a diagnostic test the patient requested would have little benefit.
- Defining “analyzed” for reporting tests in the data column: “Analyzed” means using data as part of the medical decision-making (MDM) process. Tests that don’t require an analysis still count if they are a factor in diagnosis, evaluation or treatment.
- Clarifying the definition of a “unique” test: Multiple results of the same tests during an E/M service are considered one unique test. Tests with overlapping elements are not considered unique even if they have distinct/separate CPT codes.
- Clarifying what is meant by “discussion” between physicians/other qualified healthcare professionals and patients: “Discussion” requires a direct, interactive exchange. Sending notes does not count.
Principal Care Management Services
The CPT added a new category of principal care management (PCM) codes (99424–99427) to the Care Management Services section. Unlike chronic care management and complex chronic care management, which require at least two chronic conditions, PCM focuses on medical or psychological needs caused by a single, complex chronic condition expected to last at least three months. PCM services include establishing, implementing, revising or monitoring a care plan directed toward that single condition. PCM codes can be reported by different physicians or qualified healthcare professionals in the same calendar month. Clinical documentation should reflect coordination of care among the managing clinicians.