When it comes to Medicare payment, recent focus has been on the conversion factors used to determine payment for services paid via the Medicare Physician Fee Schedule and the development of value-based payment systems. However, this has not changed the requirement that the Department of Health and Human Services (HHS) and the Centers for Medicare & Medicaid Services (CMS) take steps to reduce the incidence of improper payments per the Payment Integrity Information Act of 2019. Anesthesia and pain medicine practices should be aware of what services are considered particularly at risk for improper payments and the steps that HHS and CMS take to mitigate that risk.

CMS did scale back its activities in this area from March to August 2020 due to the Public Health Emergency (PHE). Also due to the COVID-19 PHE, the 2020 analysis used claims dated from July 2018 to June 2019. The agency also adjusted...

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