By Kate Thomas, Chief Advocacy & External Affairs Officer
On July 13, the Centers for Medicare & Medicaid Services (CMS) released the Medicare Physician Fee Schedule (MPFS) proposed rule for calendar year 2022, which outlines the proposed Medicare payment rates for 2022 and addresses other provisions including updates to the Medicare Diabetes Prevention Program (MDPP) and the Medical Nutrition Therapy (MNT) benefit. The proposed changes will be finalized in early November 2021 and will apply to Medicare Part B services furnished on or after January 1, 2022.
The proposed rule is open for comment through September 13, 2021. ADCES is conducting a full analysis of the proposed rule and will submit comments to CMS addressing areas relevant to diabetes care and education specialists.
ADCES has highlighted key provisions that may be of interest to members. Additional information can be found on the CMS fact sheet. There is also a separate fact sheet detailing proposed changes to the MDPP.
Payment Conversion Factor
CMS estimates a conversion factor of $33.58, a decrease of $1.31 from the CY 2021 conversion factor of $34.89. The conversion factor is used to calculate the payment rate for services paid under the MPFS.
Valuation for Diabetes Self-Management Training (DSMT) Codes (G0108 and G0109)
CMS did not propose any changes to the DSMT benefit or related codes- G0108 (Diabetes outpatient self-management training services, individual, 30 minutes) and G0109 (Diabetes outpatient self-management training services, group session (2 or more patients), per 30 minutes). See Table 1 for the estimated payment rates for 2022. Note, these values will not be finalized until November when CMS releases the MPFS final rule.
ADCES continues to advocate for changes to the DSMT benefit both through our legislative efforts in advancing the Expanding Access to DSMT Act (S. 2203) and through ongoing discussions with and comments to CMS. ADCES urges its members to contact their legislators and ask them to support this important legislation.
Medicare Diabetes Prevention Program
ADCES, in collaboration with other stakeholders including the Diabetes Advocacy Alliance (DAA), has been and continues to advocate for improvements to the MDPP. Through written communications, formal comment letters, engagement with congressional leaders, meetings, and other channels, ADCES and the DAA have urged CMS and the Center for Medicare and Medicaid Innovation (CMMI) to remove the barriers that suppliers face when trying to enroll in and/or deliver the MDPP. We have also addressed challenges that limit beneficiary access to the program. In the proposed rule, CMS has proposed a series of significant changes to help reduce the administrative burden on suppliers and improve beneficiary access to the services.
Below is a summary of the changes proposed by CMS for 2022:
- Waiving the Provider Enrollment Fee: CMS is proposing to remove the $599 provider enrollment application fee for all organizations that submit an application to enroll as an MDPP supplier on or after January 1, 2022.
- Shorten the MDPP Services Period to One Year: CMS is proposing to shorten the MDPP services period to from two years to one year by removing the Ongoing Maintenance sessions phase (months 13-24) of the MDPP set of services. This would apply to beneficiaries starting the MDPP on or after January 1, 2022 and would align with the National DPP.
- Redistributing Payments: As CMS is proposing to remove the Ongoing Maintenance sessions from the MDPP services period, they are also proposing to redistribute a portion of the Ongoing Maintenance session phase performance payments to certain Core and Core Maintenance performance payments. They also propose to increase performance payments for MDPP beneficiary achievement of the 5% weight loss goal, as well as continued attendance during each core maintenance interval.
ADCES is pleased that CMS has put forward these proposed changes, especially as it reflects our extensive advocacy work to push for program improvements that would make it easier for suppliers/providers to delivery MDPP services. Though an important start, additional changes are needed, especially the need to address the 5 percent weight loss threshold and other disincentives in the current model for serving lower income and marginalized populations. ADCES has also advocated for the removal of the once-per-lifetime limit and the inclusion of virtual programs as MDPP suppliers to help improve equitable access and expand reach of the program.
ADCES will provide more information to its members in the coming weeks, including opportunities for interested individuals to submit their own comments to CMS in response to this proposal.
Medical Nutrition Therapy
CMS is also proposing updates to the regulation for MNT, including the following:
- Removing the requirement that the MNT referral be made by the “treating physician.” Currently CMS regulations require the MNT referral to come from the treating physician, who they define as the primary care physician or specialist, coordinating care for the beneficiary with diabetes or renal disease. Though the proposal still does not include non-physician providers, we are hopeful that it will help improve beneficiary access to MNT and will continue to work with others, including the Academy of Nutrition and Dietetics to increase the list of referring providers.
- CMS is proposing to make a technical correction and update the payment regulation for MNT services at §414.64 to clarify that MNT services are, and have been, paid at 100% (instead of 80%) of 85% of the PFS amount, without any cost-sharing, since CY 2011.
- CMS is proposing to update the glomerular filtration rate (GFR) to reflect current medical practice. This is an important update for beneficiaries with chronic kidney disease receiving MNT services and helps to align the beneficiary’s GFR and Medicare eligibility criteria.
- CMS is also proposing to establish regulations at §410.72 for registered dietitians and nutrition professionals, similar to established regulations for other non-physician practitioners.
Stay tuned for more updates as ADCES as we review the additional provisions in the MPFS proposed rule for 2022.
ADCES Perspectives on Diabetes Care
The Association of Diabetes Care & Education Specialists Perspectives on Diabetes Care covers diabetes, prediabetes and other cardiometabolic conditions. Not all views expressed reflect the official position of the Association of Diabetes Care & Education Specialists.
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