Reimbursement: ED Providers Could See E/M, Critical Care Changes Under New Proposal

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Note:  The following article synopsis was NOT provided by AAPC. It was created by Find-A-Code/innoviHealth.

Article Overview

This article reviews selected provisions from CMS’s proposed 2022 Medicare Physician Fee Schedule and explains why they matter for emergency department and other physician practices. It focuses on proposed telehealth policy changes, split/shared visit and critical care considerations, and the expected direction of Medicare payment updates, along with the response from major physician organizations.

Why This Topic Matters

The proposal could affect how emergency department services are reported and reimbursed, while also signaling broader Medicare payment pressure for physician practices. It is relevant for coders, billing staff, compliance teams, and emergency medicine leaders monitoring proposed federal policy changes.

Article Sections

  1. Background and proposed rule overview

    Introduces the CMS calendar year 2022 Medicare Physician Fee Schedule proposed rule and highlights the main policy themes discussed in the article.

  2. Telehealth could continue for ED codes

    Summarizes the proposed extension of emergency department-related telehealth availability and the general policy context around that proposal.

  3. Split/shared visits may enter ED

    Covers proposed changes affecting split/shared visit policy for emergency department services, critical care, and teaching physician services.

  4. Expect lower conversion factor

    Describes the proposed Medicare conversion factor change and the broader payment impact discussed in the article.

  5. Public outcry

    Notes the reaction from physician organizations and the general concerns raised about the proposed payment changes.

  6. Consider commenting before deadline

    Provides the public comment timeline and the expected timing for the final rule.

What You Will Learn

  • The main topics addressed in CMS’s proposed 2022 Medicare Physician Fee Schedule
  • How the proposal could affect emergency department telehealth policy
  • What areas of split/shared visit policy are being revisited
  • Why the proposed Medicare payment update is drawing concern
  • The comment and implementation timeline for the proposed rule

Who Should Read This

  • Emergency department coders
  • Physician billing staff
  • Compliance professionals
  • Emergency medicine administrators
  • Revenue cycle teams
  • Healthcare policy readers

Codes Discussed

Code Ranges Discussed

  • CPT: 9928X

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