2022 Reimbursement Policy Impacts: What You Need to Know

Something the pandemic has taught us is not to get too comfortable with what is required because we never know when we will have to pivot next and then pivot again. With that in mind, I will give a summary of what you need to know about 2022 reimbursement changes and where to find more information about the changes. In the News I am sure most of you heard about the remarkable 5.1 percent fee schedule increase for dates of service on or after January 1. While this is the largest increase in over 30 years, you need to be aware of what you need to do to remain compliant. To read the MLN Matters article that outlines updates for the fee schedule and changes to DMEPOS payment policies, visit go.cms.gov/3G21d1X. Sequestration was suspended for Medicare fee-for-service claims during the COVID-19 pandemic. However, Congress passed a bill that extended the postponement through March 31, and reduced the sequestration rate from 2 percent to 1 percent from April 1 until June 30. To review the policy, visit bit.ly/3g1pPgy . To combat fraud and overpayments, CMS has generated a Master List of codes that are determined by CERT, OIG, and/or GAO reports to meet the payment thresholds set forth in 414(b)(1). This Master List was updated in the Federal Register on January 13 to include five orthotic codes that will require the following: Prior authorization Face-to-face encounters Written order prior to delivery (WOPD) To read details about these items, visit go.cms.gov/3IKMvy8 . Medicare is extending prior authorization to five orthotic codes added to the master list: L-0648, L-0650, L-1832, L-1833, and L-1851. This prior authorization procedure will be implemented in three phases according to region. Phase 1: New York, Illinois, Florida, and California will begin on April 13. Phase 2: Maryland, Pennsylvania, New Jersey, Michigan, Ohio, Kentucky, Texas, North Carolina, Georgia, Missouri, Arizona, and Washington will begin July 12 . Phase 3: Remaining states implementation will begin October 10. Effective April 13, face-to-face encounters are required for these codes and must take place within six months prior to the written order. Telehealth services are acceptable as long as they meet the CMS requirements. Suppliers must maintain written order/prescription and the supporting documentation of the face-to-face encounter and make them available to CMS and its agents upon request. For items on the face-to-face encounter list, a complete order is required prior to the item’s delivery. This is a change from all other items which require a standard written order prior to claim submission. To review the related CMS documentation regarding this, visit go.cms.gov/32BFwYG . What do these changes mean for your practice and how can you ensure compliance? By the time this article is released, the Medicare increase will be in full effect. Be sure your software system is up to date with the fees you are expecting, and the adjustments are accurate based on the released fee schedule. Use this as an opportunity to review any other payer contracts you have that are based on a percentage of Medicare’s fee schedule. For example, if you have a current contract that states X amount of Medicare’s Current Fee Schedule, read the fine print of the contracts. Are the other payers due for an increase as well? Contact your payer representative and start the conversations. Make sure your billing staff is fully aware of the sequestration guidelines, dates, and deductions. Ensure your staff is correctly allocating the sequestration when posting and receiving payments. Prior authorization, face-to-face encounters, and WOPD are significant developments, and it is suggested that you review the complete article and educate your staff. I recommend everyone involved understands the how and why CMS is implementing these changes. If a prior authorization, face-to-face encounter, or WOPD is required for any device, this should be checked as part of your internal audit and/or your work in progress. Assign an individual in your office to look for these updates year-round, manage their implementation, and educate the rest of the staff. Change is inevitable. These topics are just a snapshot for this period in time. It is up to you as a provider to keep up to date with all changes, educate your staff, and remain in compliance. Erin Cammarata is president and owner of CBS Medical Billing and Consulting. She can be contacted at erin@cbsmedicalbilling.com.

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