On September 10, the AUA submitted comments in response to the Calendar Year (CY) 2022 Medicare Physician Fee Schedule. Our comments to the Centers for Medicare & Medicaid Services (CMS) focus on 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 update. 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, such as CPT code 52442 Cystourethroscopy, with insertion of permanent adjustable transprostatic implant; each additional permanent adjustable transprostatic implant (List separately in addition to code for primary procedure), which is estimated to experience an overall 22.04% cut based on CY 2022 proposals. The AUA also signed onto comment letters regarding the proposed clinical labor rate update submitted to CMS by the Clinical Labor Coalition and the Alliance for Specialty Medicine.
The AUA previously met with CMS, as detailed in the September 1 AUA Public Policy Update, to discuss these issues and expects CMS to issue the CY 2022 Medicare Physician Fee Schedule final rule in early November 2021. The AUA’s finalized comment letter is attached for your review.