CY 2022 Physician Fee Schedule Proposed Rule

Your Digital Health Strategy: CY 2022 Physician Fee Schedule Proposed Rule

Reimbursement. It is by far the biggest roadblock to healthcare organizations’ digital health strategies, and rightly so. In the wake of COVID-19, many organizations are hesitant to take on risk without a guaranteed return on investment. Although Medicare and commercial payers expanded coverage for certain digital health services during the public health emergency (PHE), what happens when the PHE ends? It’s a question with which organizations continue to struggle as they try to prioritize competing health information technology investments.

The good news is that reimbursement may be less of an impediment going forward thanks to several proposals in the CY 2022 Medicare Physician Fee Schedule Proposed Rule. This article discusses five proposed changes and how healthcare organizations can use them to initiate a digital health program or accelerate an existing one.

  1. CMS takes steps to cover a wider breadth of telehealth services beyond the PHE. Certain services covered temporarily during the PHE may be covered for longer—through at least December 31, 2023. This includes the following:
    • Domiciliary, rest home, or custodial care services for established patients (99336-99337)
    • Home visits for established patients (99349-99350)
    • Emergency department visits levels 1-3 (99281-99283)
    • Nursing facility discharge day management (99316-99316)
    • Psychological and neuropsychological testing (96130-96133)CMS will continue to evaluate whether these services should be permanently added to the telehealth list following the PHE.How to leverage this proposed change: Look at this list to determine whether it makes sense to expand these virtual care service lines. Do you have enough patient volume to sustain a lucrative strategy? How can you effectively market these services to patients and their caregivers?
  1. CMS may permanently adopt virtual check-in code G2252. This code, originally approved on an interim basis, may be officially adopted if the CMS proposal sticks. G2252 denotes brief technology-based services (e.g., virtual check-in) by a physician or other qualified healthcare professional. Providers can only report this code for an established patient. Another caveat is that the service can’t originate from a related evaluation and management (E/M) service provided within the previous seven days. It also can’t lead to an E/M service or procedure within the next 24 hours or soonest available appointment. This code requires 11-20 minutes of medical discussion.How to leverage this proposed change: If providers don’t already render virtual check-ins, now is the time to start assessing and redesigning workflows. It’s also the time to determine whether patients can benefit from this service that’s intended for scenarios where the acuity of a patient’s problem is not necessarily likely to warrant an in-person visit, but when a provider needs more than 5-10 minutes to make that assessment. If so, patient awareness of this service line (and how to use it) becomes paramount.
  2. CMS proposes new code for remote therapeutic monitoring (RTM). RTM (CPT codes 989X1, 989X2, 989X3, 989X4, and 989X5) closely resembles remote physiological monitoring (RPM) with a few notable exceptions. First, RTM allows for the collection of non-physiologic data to monitor musculoskeletal system status, respiratory system status, therapy adherence, and therapy response. Second, patients can self-report RTM data, or they can digitally upload it via a medical device. Third, nurses and physical therapists are the intended providers of RTM.How to leverage this proposed change: Initiate conversations internally about whether it makes sense to offer RTM as a complement to an RPM program or as a stand-alone service. RTM offers the promise of broader use cases and therefore may even more lucrative than its RPM counterpart in the long-run.
  3. CMS proposes several advantageous changes related to telehealth for certain mental health services. However, the physician or practitioner furnishing the mental health services must provide an in-person, non-telehealth mental health service within six months prior to that telehealth service and at least once every six months thereafter. Second, CMS proposes to permanently cover audio-only communication when used for certain mental health services furnished to established patients in their homes. Providers will need to use a modifier to signify that they had the ability to provide two-way, audio/video technology but used audio-only because of beneficiary choice or limitations.How to leverage this proposed change: Provider education is a big piece of this because providers will need to know how to comply not only from a scheduling standpoint but also from a modifier standpoint. The good news is that these proposed changes make it easier for providers to maintain existing relationships with patients currently using audio-only telehealth.


  1. CMS may provide greater flexibilities for rural health centers (RHC) and federally-qualified health centers (FQHC) rendering mental health services. More specifically, both entities would be able to report and receive payment for mental health visits furnished via real-time telecommunication technology in the same way they currently do when visits take place in person. This includes audio-only visits.How to leverage this proposed change: Education. Oftentimes RHCs and FQHCs are left in the dark when it comes to regulatory changes. They can definitely benefit from knowing the payment implications of telehealth visits (including audio-only visits) going forward. This can have a big financial impact and potentially justify service line expansion.


With the publication of the CY 2022 Medicare Physician Fee Schedule Proposed Rule, all signs seem to be pointing toward expanded Medicare coverage of digital health services. Hopefully commercial payers will follow suit, making it easier for healthcare organizations to commit to a long-term digital health strategy. Consider leveraging these developments to launch or accelerate digital health efforts going forward.