ISASS Comments on 2021 Medicare Physician Fee Schedule Proposed Rule

ISASS submitted a comment letter to the Centers for Medicare and Medicaid Services (CMS) on the 2021 Medicare Physician Fee Schedule Proposed Rule on October 2, 2021.

The ISASS letter addressed several areas of interest and relevance to ISASS members, including the proposed reduction in Medicare physician payments for 2021. In the proposed rule, CMS proposed an 11% reduction in the Medicare conversion factor used to calculate physician payments. ISASS pointed out the unfairness of imposing a substantial payment reduction on physician and physician practices facing shortages and difficulties due to the ongoing COVID-19 emergency. ISASS urged CMS to reverse the proposed reduction and maintain the current conversion factor, thus eliminating the resulting payment reductions.

In addition, the ISASS letter supported the CMS nomination of CPT code 22867, “Insertion of interlaminar/interspinous process stabilization/distraction device, without fusion, including image guidance when performed, with open decompression, lumbar; single level,” as potentially misvalued. ISASS indicated a willingness to provide additional information to the agency in their efforts to determine appropriate valuation for this procedure.

ISASS also commented on the proposed continuation of the expanded list of services eligible for telehealth under the CMS COVID-19 Emergency Declaration. ISASS stated this expanded access has been critical to practices in providing patients with non–face-to-face access during the Emergency Declaration period. CMS called for the policy to remain in place through at least December 31, 2021.

CMS will publish the Medicare Physician Fee Schedule Final Rule in December 2020, to go into effect on January 1, 2021.

A copy of the ISASS letter can be found here: ISASS Physician Fee Schedule Proposed Rule Comment Letter