Medicare Physician Fee Schedule 2022 Final Rule Summary

November 15, 2021

On November 2nd, the Centers for Medicare and Medicaid Services (CMS) issued the CY 2022 Medicare Physician Fee Schedule Final RuleThis year’s rule finalizes several significant Rural Health Clinic (RHC) policies originally proposed in summer 2021, which NARHC summarized here.

Following NARHC’s analysis, NARHC submitted comments to CMS on each RHC provision, and as you can read below in more detail, NARHC is very pleased with the ways CMS recognized and incorporated these comments.

“We can tell CMS is listening,” said Bill Finerfrock, Executive Director of NARHC. “Over the years, new Medicare benefits tended to come to the RHC program last. Thankfully, that is not the case this year, as the “mental health services via telehealth” benefit will be coming to RHCs on day one. We still have some work to do in the future on remote patient monitoring, but this year’s final rule is a very positive step.”

The final rule also contains some important clarifications regarding grandfathered RHCs.

“We were concerned that CMS had not yet clearly indicated how grandfathered RHCs could change addresses or change ownership without losing their grandfathered status,” said Nathan Baugh, Director of Government Affairs for NARHC. “However, this rule makes it clear that grandfathered RHCs that retain their CCN through a move or CHOW will retain their grandfathered status. We understand that there still may be some additional clarification necessary as the MACs move to institute clinic-specific upper payment limits, but CMS has been responsive thus far and we are hopeful that new guidance will be released soon.”

For a detailed summary of the RHC-relevant provisions of the 2022 PFS final rule please visit and email with any questions.