In a letter to Administrator Honorable Chiquita Brooks-LaSure at the Centers for Medicare and Medicaid Services (CMS), dated September 10, 2021, David Karp, MD, on behalf of the American College of Rheumatology (ACR), responded to the CY 2022 Physician Fee Schedule and Quality Payment Program proposed rule published in the Federal Register in July 2021. The full communication can be found on the ACR website.

The ACR offered comments regarding the policies dealing with the decreased conversion factor, practice expenses, evaluation and management split visits, telehealth flexibilities, Part B calculations, and the Quality Payment Program.

Regarding the decreased conversion factor and practice expenses, the ACR noted that they opposed the decrease, urging the CMS to maintain a factor of $34.8931 until at least 2023 and asked for a similar 4-year transition to implement the clinical labor pricing update.


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Regarding evaluation and management split visits, the ACR asked CMS to continue monitoring how these codes were updated and operationalized. The ACR acknowledged the need to fine tune the rules for these visits but wanted to ensure that providers can successfully implement the revised policy for split or shared visits. For telehealth visits, the ACR recommended permanently adding this service that was adopted during the current public health emergency, as well as permanently adopting coding and payment for code G2252.

In response to changes in payment methods for self-administered drugs, the ACR strongly opposed the recommended payment adjustments on the grounds that they may negatively impact patient access. The ACR urged CMS not to implement the exclusion of self-administered formulations of Orencia and Cimzia from the Part B calculations.

The ACR also commented on the proposed provisions in the Quality Payment Program saying that while they supported efforts toward greater data standardization and interoperability, they were concerned that providers will be required to meet interoperability standards that their electronic health records (EHRs) may not support. Therefore, the ACR asked the CMS for an environmental landscape assessment of EHRs software capabilities with a focus on EHRs used by small and rural practices.

The implementation of digital quality measures was also supported by the ACR, but efforts to meet the standards set out by 2025 may disproportionately affect specialists.

The ACR urged the CMS to consider the following steps as the medical community moves to digital quality measures:

  • Assess successful strategies of existing EHR systems with regard to the adoption and incorporation of fast health care interoperability resources (FHIR) and interoperability standards, as described by the Office of the National Coordinator for Health Information Technology (ONC) and CMS. The cost to providers in accessing all relevant functionality may also be evaluated.
  • Review the information required to support the CMS measures compared with available FMIR resources and identify the gaps where the elements do not exist to support the evaluation of digital quality measures.
  • Define the role of CMS in the development of new FMIR resources to support the transition to and development of new digital quality measures.
  • Understand and determine the role that measure stewards and developers, including organizations with qualified clinical data registry measures, will have during the transition to digital quality measures.

The letter from the ACR also included comments regarding closing the health equity gap, scoring and the MIPS value pathway, as well as MIPS cost, interoperability, and improvement activities categories.

The ACR said it remained committed to working with CMS to ensure patients receive quality care. “During this [public health emergency], providers must be supported via appropriate reimbursement, embracing telehealth, alleviating administrative burden, and streamlining programs designed to advance quality care.”