On September 13, the AAO-HNS submitted a comment letter to the Centers for Medicare & Medicaid Services (CMS) on the CY 2022 Medicare Physician Fee Schedule and Quality Payment Program proposed rule. The Academy’s comments focused on the following issues most significantly impacting the specialty:
- Decrease to the conversion factor;
- Rank order anomalies in the family of certain audiology codes;
- Changes to E/M proposals;
- Valuation of codes affecting otolaryngology;
- Clinical labor pricing;
- Telehealth services;
- Scope of practice;
- Appropriate use criteria; and
- Quality Payment Program (QPP).
The Academy anticipates the final rule to be released in early November. AAO-HNS Advocacy staff will provide an analysis of CMS’ response to our comments and final policies for calendar year 2022 shortly after the rule’s release.
