The 1,747 PAGE CMS 2022 Proposed Fee Schedule

(Final Rule) was released last night.

Here are a few highlights:

  • The 15% Reduction in PTA/COTA Reimbursements Begins 1/1/22
    • CO and CQ Assistant Modifiers will be required per the same 10% De Minimis rule we’ve been aware of since 1/1/20
      • These modifiers are required today
      • But beginning 1/1/22 the modifiers will trigger the discounted reimbursement rates
    • Systems 4PT’s  “Recommend Units” functionality is compliant with these 10% De Minimis rules.
    • If your Staff have any questions about the 10% De Minimis rule or “PTA/COTA” modifiers, please contact Support.
      • An observation: The 10% De Minimis rule DOES NOT apply to PTA/OTAs treating incident to an MD (assistants who work in physician owned practices, known as POPs).
        • We (outpatient rehab) need better representation.
  • “Assistant Supervision Requirements” – Outpatient Rehab
    • During the PHE, CMS altered the definition of “assistant supervision” to mean “any supervising therapist who could be contacted”…  For example, by phone
    • As of 12/31/21, CMS proposes that the previous “line of site” supervision rules return.
  • Calendar Year 2022 Medicare Fee Schedule Adjustments
    • CMS announced a 3.75% decrease in payment for outpatient therapy services in CY 2022 compared to CY 2021.
    • The 2013 Medicare Sequestration lowered Medicare reimbursements by 2%
      • The 2020 CARES Act halted the 2% sequestration for 2020 and ’21 because of the PHE
      • The 2% sequestration is scheduled to return 1/1/22, lowering payments by an additional 2% in 2022.
    • Outpatient rehab saw a 2.6% decrease in the Medicare fee schedule that began 1/1/21.

Adding it all up:

  • So for PTs and OTs, the 2022 Medicare Fee schedule is 8.1% lower than the 2019 fee schedule.
  • Including the 15% reduction, for PTAs and COTAs, the 2022 Medicare Fee schedule is 21.9% lower than the 2019 fee schedule.
  • Medicare Telehealth Services
    • The proposed rule assumes that the public health emergency (PHE) will be over on 12/31/21
    • As such, Medicare proposes to no longer reimburse telehealth for outpatient rehab
      • Note: Once again, PT/OT treating for POPs can charge Medicare telehealth
    • It is reasonable to expect that the other major payers will follow the CMS lead and discontinue covering telehealth for outpatient rehab.
      • We’ll have to wait and see
    • For perspective, telehealth visits represented only 0.3% of all visits in June, ‘21


CMS is rebranding MIPS as MVP, “Medicare Value Pathway”.  This had been previously discussed.

MVP Performance thresholds will increase from 60 point minimum in ’21 to 70 points in ’22, 80 points in ’23 and to 89 points in ’24.

Your practice is well positioned for these changes:

  • 87% of Systems4PT practices are trending toward 100 points in ‘21
  • Systems4PT practices average 2021 trending MIPS score is 98.89 points, well above expected thresholds.

Clearly, CMS is planning to “put teeth” into MVP.. meaning, they are planning to make it harder to avoid penalties…

This is how the MVP “rewards” will increase from today’s max of 1.7% to 3%, 5% or more.

Finally, CMS clearly intends to make MVP MANDATORY for all practices in the future.

  • The above is clearly stated, but no timeline is given.
  • This will dramatically increase the number of untrained MIPS/MVP practices, again further bolstering penalties which then fund rewards for high scoring practices.

Looking ahead at MIPS/MVP:

  • We are pleased that the average Systmes4PT practice is receiving ~ $2,400 in MIPS bonus dollars in ‘21
  • And we are confident (that as a team) Systems4PT practices are positioned to benefit from the Medicare Value Pathway in the near-term future.