Dr. Meena Seshamani
First, let me catch up on a CMS press release from a few days ago. CMS is the Centers for Medicare and Medicaid; thus, it has internal directors for Medicare and for Medicaid. CMS has announced the new Director of the Center for Medicare is Dr. Meena Seshamani. Press release here. She has an MD/PhD, the PhD being in Health Economics from Oxford. She's an otolaryngologist trained at Hopkins.
PFS Rule for CY2022
With a triplet of press releases, CMS releases proposed Physician Fee Schedule and other outpatient proposals for CY2022. This kicks off a 60 day comment period.
- Press release here.
- Fact sheet here.
- The fact sheet weighs in at 6500 words, which may be a record.
- For me it prints as 17pp.
- Special fact sheet about Diabetes Prevention Model (MDPP) here.
- There's also a separate 21-page PDF fact sheet for quality measurement program changes, here.
- Rulemaking permalink here.
- Published version July 23, 2021, 86 FR 39104, 804pp.
- Link here. It's an awesome 60mb this year. And locked (no highlighting)
- I've made a version which is 30mb and unlocked (allows notes and highlighting), in the cloud here.
- Inspection copy aka typescript version here.
- It's an imposing 1747 pages long.
CMS established a Medicare benefit for diabetes prevention programs several years ago, based on a demo project by the YMCA that was cost-saving in the Medicare population. The program has never really taken off and was probably really torpedoed by the COVID epidemic. CMS proposed some changes to make it more friendly to those who would fund and provide the programs.
The financial changes will dribble in; status quo CMS pays 80% in 2022. CMS pays 85% in 2023-2026 (thanks!). CMS pays 90% in 2027-2029, then 100% from 2030 forward.This change in Medicare payment (from 80% now to 100% per CAA 122) is described over 3 pages.
Colon cancer copays have been bouncing around since 2014; see Howard et al. here.
With the RPM (and now RTM and we expect CBT) codes, CMS has opened up its view of what is "furnished in the office" and "incident to" (it now includes the take-home monitors), but this is still contingent on the physician "incident to" benefit which doesn't apply to psychologists or physical therapists.
For a vender's listing of the RPM CPT codes, here. 99454, 30 days RPM service, is priced for a $1000 "heart failure patient physiol monitoring equipment (EQ392)" (table 16 here; see also here) with a 5 year life, prorated at $49 value per month in the AMA RVU tables (subscription). After various obscure calculations for practice expense, the CMS payment for 99454 is circa $63.