COA Submits Comments on Proposed 2022 Medicare Physician Fee Schedule

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COA applauds extension of telehealth services but expresses deep concern about changes to Evaluation and Management code set

WASHINGTON, D.C., UNITED STATES, September 13, 2021 / — Today, the Community Oncology Alliance (COA) submitted formal comments to the Centers for Medicare & Medicaid Services (CMS), regarding the proposed 2022 Medicare Physician Fee Schedule (MPFS).

In the letter, COA expresses some support and significant concerns with the 2022 MPFS Proposed Rule. While applauding CMS’ decision to extend and allow flexibilities with telehealth services as well as efforts to expand access and minimize the cost of cancer screenings, COA is extremely concerned about adjustments to the CY 2022 MPFS conversion factor and several changes to Evaluation and Management (E/M) codes.

Click here to read COA’s full comment letter on the 2022 MPFS Proposed Rule.

COA’s biggest concern is that CMS is proposing a 2022 MPFS conversion factor of $33.58, a $1.31 decrease from 2021. Modeling with real data from practices shows that these cuts will be significant and severe for practices, resulting in, for example, up to a 14.8 percent cut in reimbursement for chemotherapy and other cancer drug administrations. These cuts threaten the financial health of community oncology practices who are already shouldering the burden of a public health emergency (PHE).

Community oncology practices continue to face enormous financial and operational pressures during the ongoing COVID-19 pandemic and PHE. In a recent internal survey of nearly 100 COA member practices, 73.9 percent of respondents reported facing “significant additional expenses” since the beginning of 2021 in dealing with the pandemic, and 38.9 percent reported spending 11-20 percent more in unanticipated costs for PPE, staff recruitment and retention, and more. Additionally, 63.9 percent of practices report that the emotional and mental health of staff has gotten worse since the beginning of the year, reflecting stress from the still raging COVID-19 pandemic and PHE.

As part of its recommendations, COA is requesting more information on the conversion factor changes and asks CMS to strongly reconsider any payment cuts to oncology providers offering essential health services during a pandemic. As noted in a recent letter to Congressional leaders, America is facing very real threats to the nation’s cancer care infrastructure, with few concrete proposals in place to address them.

Read COA’s full CY 2022 MPFS Proposed Rule comment letter at


About the Community Oncology Alliance
The Community Oncology Alliance (COA) is a non-profit organization dedicated to advocating for community oncology practices and, most importantly, the patients they serve. COA is the only organization dedicated solely to community oncology where the majority of Americans with cancer are treated. The mission of COA is to ensure that patients with cancer receive quality, affordable, and accessible cancer care in their own communities. More than 1.5 million people in the United States are diagnosed with cancer each year and deaths from the disease have been steadily declining due to earlier detection, diagnosis, and treatment. Learn more about COA at

Nicolas Ferreyros
Community Oncology Alliance (COA)
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