REIMBURSEMENT PAGE
By DEVON BERNARD
The Ever-Evolving Reimbursement Scene Developments in prior authorization, competitive bidding, audit programs, and more
Editor’s Note—Readers of Reimbursement Page are eligible to earn two CE credits. After reading this column, simply scan the QR code or use the link on page 18 to take the Reimbursement Page quiz. Receive a score of at least 80 percent, and AOPA will transmit the information to the certifying boards.
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HIS PAST YEAR MAY not have
been as disruptive as 2020, but 2021 was still a busy year. We saw the full implementation of prior authorization take effect. We saw the implementation of Round 2021 of the competitive bidding program (CBP), which for the first time included off-the-shelf orthoses. We saw the reintroduction of the Target, Probe, and Educate (TPE) audit program. And we experienced many other smaller, but just as significant, changes. This month’s Reimbursement Page offers a recap of some of the 2021 changes that you may have missed, overlooked, or forgotten—and takes a sneak peek at some updates in store for 2022.
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NOVEMBER/DECEMBER 2021 | O&P ALMANAC
Fee Schedule Updates
The best place to start is at the beginning—and in this case, that’s the 2021 durable medical equipment, prosthetics, orthotics, and supplies (DMEPOS) fee schedule. The annual Medicare fee schedule increase for DMEPOS services and items is based on a combination of two factors: 1) the change in the Consumer Pricing Index for All Urban Consumers (CPI-U) from June to June of the previous year, and 2) the annual multifactor productivity adjustment (MFP). The CPI-U for June 2019 through June 2020 was 0.6 percent, and the annual MFP adjustment was -0.4 percent. This resulted
in roughly a 0.2 percent increase in the 2021 DMEPOS fee schedule. Looking to next year, the CPI-U from June 2020 to June 2021 was 5.4 percent. The official MFP has not been released; however, it is expected to be between 0.2 and 0.4 percent. Given these numbers, it is possible that the 2022 DMEPOS fee schedule could see an increase between 5.0 and 5.2 percent. What about the mandatory 2 percent sequestration-based reduction to all Medicare payments? At the start of the COVID-19 public health emergency (PHE), the 2 percent sequestration-based reduction was suspended until Dec. 31, 2020, but was later extended to March 3, 2021. Then, the March suspension was extended to the end of this year. Currently, there is no indication that the suspension will continue past Dec. 31, 2021. The fee schedule also was impacted by the implementation of Round 2021 of the CBP—and not just for suppliers who won contracts in one or more of the 130 competitive bid areas (CBAs). The Social Security Act requires “that the payment determined under the competitive bidding program be used to adjust the fee schedule amounts that would otherwise be used in making payment for DMEPOS furnished outside of the competitive bidding areas for these items.” This means there is a statutory
