Tuesday, November 1, 2022

CMS Final Rules for CY2022: OPPS and PFS

 After work hours on November 1, 2022, CMS released the Outpatient (OPPS) and Physician (PFS) final rules.

Home page for upcoming CMS documents at Fed Reg:


Find the OPPS final rule (inspection copy) here (1764pp):


Find the PFS final rule (inspection copy) here (3304pp):


Find association materials:

PFS Press Release here.

PFS Fact Sheet on shared savings here and on general topics here.

OPPS Press Release here.

OPPS Fact Sheet here.

Final OPPS to appear here 11-23:


Final PFS to appear here 11-18:



I haven't digested these mountains of rulemaking, but one interesting bit.  In the OPPS system, CMS usually packages or bundles any services represented as an add-on code.  For Software as a Service, CMS will be able to pay add-on codes that are SaaS.  CMS states they will continually review and evolve policy in the software area.

In PFS rulemaking, CMS determines newly this fall that a stool cancer test (FIT or Cologuard) is part of a continuous process with a follow-up colonoscopy, so that, the colonoscopy does not require a copay when triggered by a stool test.  However, CMS declined, at this time, to extend the same logic to LBX tests as the first test.   This makes no sense to me; their own logic applies equally to stool or LBX tests.  To be continued, I’m sure

In PFS rulemaking, CMS had uber-complicated rules for discarded drugs and related manufacturer rebates (it's eye-crossing).   See a JAMA op ed on this change, December 19, Gross et al., here, research data O'Donoghue here.