Today, FAH submitted comments to CMS on the CY 2022 Physician Fee Schedule Proposed Rule. The rule, which affects payments beginning January 1, 2022, encompasses several proposals important to FAH members. FAH offered several recommendations related to telehealth, appropriate use criteria, physician self-referral, and quality reporting.

Key FAH comments include:

• Urging CMS to extend temporary telehealth codes through December 2023 and requesting flexibility on how telehealth providers meet semi-annual requirements for in-person visits for mental health services, audio-only requirements, and documentation and supervision requirements;
• Recommending that CMS mitigate 30%+ payment reductions for cardiac ablation services;
• Urging further delay of payment denials related to appropriate use criteria (AUC) for diagnostic imaging services and making AUC coding recommendations to ensure payment and compliance;
• Asking for clarifications to improve proposed modifications  to the Stark self-referral law; and
• Recommending changes, delays, and modifications to quality proposals for physician services.

Additional recommendations and supporting arguments are in the full letter, which can be read here.