On July 13, 2020, the Centers for Medicare & Medicaid Services (CMS) released the 2022 Medicare Physician Fee Schedule proposed rule (which also includes updates for the Quality Payment Program and other Medicare Part B payment policies). The AUA submitted comments on the proposed rule on September 10.

Related: View the AUA’s Top Takeaways on the proposed rule for the CY 2022 Medicare Physician Fee Schedule.

The AUA’s comment letter specifically addresses the following:

• CMS’ Proposed Update to Direct Practice Expense Clinical Labor Rates
• Implementation of Telehealth and Other Services Involving Communications Technology
• 010-day and 090-day Global Period Codes Policies
• CY 2022 Identification and Review of Potentially Misvalued Services
• Proposed Valuation of Specific Codes for CY 2022 (Periurethral Adjustable Balloon Continence Devices)
• Split (or Shared) Evaluation and Management (E/M) Visits
• Quality Payment Program Provisions

The AUA placed particular emphasis on CMS’ proposed update to the direct practice expense (PE) clinical labor rates. This component of the direct PE inputs formula has not been updated since CY 2002 and would have a significant negative impact on reimbursement for urological procedures that involve high supplies and equipment input costs.

The AUA also commended CMS for its flexibility in telehealth services in the context of the COVID-19 public health emergency and its thoughtful implementation of statutory changes to Medicare telehealth policy and urged them to continue data collection and analysis on recently added telehealth services, urged CMS to implement recently revised values of office/outpatient Evaluation & Management visit codes into all 010-day and 090-day global period codes, thanked CMS for accepting the RUC’s recommendation on carrier pricing for four new periurethral adjustable balloon continence device procedures, and submitted comments on CMS’ proposals with respect to the Quality Payment Program and MIPS Value Pathways (MVPs).