CMS Issues 2022 PFS, Delays Changes to Pain Coding but Directly Quotes AACIPM Letter
CMS has released the final physician fee schedule for 2022, making updates to Medicare Part B payment policies, coverage of opioid use disorder services furnished by opioid treatment programs, requirements for electronic prescribing for controlled substances for a covered Part D drug under a prescription drug plan, and more.
This release comes on the heels of an open comment period in which CMS requested information from stakeholders related to the healthcare settings and practitioners that furnish non-opioid pain management, the resources involved in treating chronic pain, and how CMS might design new codes that will better enable health providers to classify and treat pain. In response, AACIPM had issued recommendations related to the creation of standalone pain codes, both time-based and value-based, and the need for CMS to ensure that a wide-range of clinicians are able to provide guideline-concordant services. CMS received over 1,900 public comments related to potential separate coding for chronic pain management but delayed making changes, promising to “carefully consider this feedback for future rulemaking.” However, the efforts of AACIPM’s many stakeholders were not for naught, as recommendations #2 and #4 from our letter were directly quoted by CMS in their summary of public comments, as they wrote: One commenter recommended that “CMS establish a multi-stakeholder working group to determine operational details and resource allocation” and requested that CMS “establish a pilot program using innovative payment methodologies.”