On November 2, 2021, the Centers for Medicare and Medicaid Services (“CMS”) released its Final Medicare Physician Fee Schedule for 2022 (the “Final 2022 MPFS”), revising certain payment policies for services provided to Medicare beneficiaries by healthcare practitioners. These policies take effect on January 1, 2022.
The Final 2022 MPFS contains several provisions aimed at expanding billing opportunities for care provided by non-physician practitioners (“NPPs”) such as physicians assistants and by other qualified healthcare practitioners (“QHCPs”) such as occupational and physical therapists. One important expansion provides billing and payment directly to Physician Assistant(s).
Previously, CMS allowed healthcare professionals such as physicians, NPs, CNSs, physical therapists, psychologists, licensed clinical social workers, and others to receive direct Medicare Part B (“Part B”) payment under their own name, while requiring Part B payment for PA services be made directly to a PA’s employer. Now, starting on January 1, 2022, “payment will be made to a PA for their professional services, including services and supplies provided incident to their services,” finally allowing PAs to participate in certain practice opportunities that were previously only available for physicians and other NPPs. This change creates new opportunities for PAs, likely resulting in increased access to care.
New Practice Opportunities for Physicians Assistants
PAs who choose to receive payment directly from Medicare for their services will be able to:
- Form medical corporations/practices with other PAs in the same specialty
- Seek work as self-employed independent contractors
- Reassign Medicare payment rights to any employer, facility, or billing agent
- Receive reimbursement for “carved out” services when working in a Rural Health Clinic (“RHC”) or Federally Qualified Health Center (“FQHC”)
New Opportunities for Digital Health Companies to Leverage Physician Assistants
Telehealth and remote patient monitoring companies who use a network of contracted physicians and NPs can now add PAs to their roster of providers. While physicians and NPs have long been able to reassign their Medicare billing rights for Part B services, allowing the medical practice arm of the company to bill Medicare directly for their services, PAs have not had the same opportunity because they were not able to reassign their billing rights. Now that CMS is allowing payment for PA services directly to a PA, digital health companies with a medical practice arm can add PAs to their network of providers as contractors and, subject to state laws that govern companies that render healthcare services (e.g., corporate practice of medicine doctrine), be paid directly for PA services.
State and Scope of Practice Limitations Remain
The ability to receive payment directly for services will likely increase access to PA services, but as CMS notes, PA services will still be required to be furnished under the supervision of a physician and PA services are only covered when furnished in accordance with State law and scope of practice rules. The Final 2022 MPFS will not override the several remaining states that prohibit PA direct payment. In those states, PAs and their employers must continue to rely on other Medicare billing options such as split/shared billing in a facility and billing under the “incident-to” rule in an outpatient setting.
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