Medical Billing and Coding Service Changes to Expect in 2022

To make sure your strategic decisions around medical billing and coding services are always up to date, we keep our eye on changes across the industry.

2022 is a year shaped by a pandemic, but at the same time, the normal changes you expect to see are impacting your decisions around medical billing services and how you should be evaluating medical billing solutions. To get you off to a strong start in 2022, here is a look at five changes we believe will have an impact on your decisions, and even how you evaluate medical billing and coding companies.

1. New COVID Codes Could Make You Reevaluate Your Medical Billing Solutions
As you’re rethinking your medical billing services, you’ll want to keep an eye on new codes that are emerging in response to the COVID-19 pandemic.

The Centers for Medicare & Medicaid Services (CMS) and Centers for Disease Control and Prevention (CDC) have both said that in April of 2022 providers will be navigating three new ICD-10-CM and seven new procedure codes for COVID-19 vaccines and therapeutics. This announcement is part of the move to a semi-annual coding update according to the Inpatient Prospective Payment System (IPPS) Final Rule for the 2022 fiscal year.

ICD-10-CM Codes
On the ICD-10-CM side, these are the codes that should be implemented as of April 1, 2022:

  • Z28.310: Unvaccinated for COVID-19
  • Z28.311: Partially vaccinated for COVID-19
  • Z28.39: Other underimmunization status

These codes will hold a “Non-CC” designation for IPPS, falling under MS-DRG 951. Now is a good time to begin education and training for coding staff and discussing implementation. You may even consider working with medical billing companies that are already up to date on how to use these codes.

PCS Codes
The procedure codes below should be implemented starting on April 1, 2022:

  • XW013V7: Introduction of COVID-19 vaccine dose 3 into subcutaneous tissue, percutaneous approach, new technology group 7
  • XW013W7: Introduction of COVID-19 vaccine booster into subcutaneous tissue, percutaneous approach, new technology group 7
  • XW023V7: Introduction of COVID-19 vaccine does 3 into muscle, percutaneous approach, new technology group 7
  • XW023W7: Introduction of COVID-19 vaccine booster into muscle, percutaneous approach, new technology group 7
  • XW0DXR7: Introduction of fostamatinib into mouth and pharynx, external approach, new technology group 7
  • XW0G7R7: Introduction of fostamatinib into upper GI, via natural or artificial opening, new technology group 7
  • XW0H7R7: Introduction of fostamatinib into lower GI, via natural or artificial opening, new technology group 7

Providers will need to verify that their chargemaster is updated where appropriate and that billing and coding staff are aware of changes to the CPT codes, discussing clinical documentation and auditing with leadership where appropriate. They may even consider a new relationship with medical billing and coding companies for support.

2. New CPT Codes Might Change Your Thoughts on Medical Billing and Coding Companies
The 2022 CPT code set included 405 editorial changes. The new code book features 24 vaccine-specific codes to help efficiently report and track immunizations and services in response to the coronavirus pandemic. These changes also include 249 new codes, 63 deletions, and 93 revisions. A good number of these, over 40%, are tied to technology services described in Category III CPT codes.

They also include 24 vaccine-specific codes to efficiently report and track immunizations and administrative services. In August, the American Medical Association (AMA) announced two vaccine-administration codes to be used in reporting third doses of COVID-19 vaccines from Pfizer and Moderna. In September, the association also announced eight new vaccine administration and vaccine codes for the Pfizer tris-sucrose formulation and the Pfizer and Moderna boosters [1].

3. Implementation of The No Surprises Act
The No Surprises Act (NSA) and its protection against surprise medical bills have been discussed for a while, but it takes effect in 2022.

The act was intended to keep insured patients from unintentionally receiving care from hospitals, doctors, or other providers that are out of network since this often places financial burdens on consumers when out-of-network claims are denied or billed at higher cost sharing rates. The federal government has estimated that the NSA will apply to around 10 million out-of-network surprise medical bills each year.

For providers, implementation will mean that doctors, hospitals, and other covered providers will be prohibited from billing patients more than the in-network cost sharing amount for these medical bills. The act additionally establishes a process to determine the payment amount for surprise, out-of-network bills, including negotiations and an independent dispute resolution (IDR) process. The surprise billing guidelines will apply in specific ways to emergency services, post-emergency stabilization services, and non-emergency services provided at in-network facilities. Providers do have the option to ask consumers to waive their rights.

After implementation, states will act in a primary role enforcing NSA rules against health providers while the federal government will act as backup. The Department of Health and Human Services has proposed conducting an average of 200 investigations per month (random or targeted) into violations, starting this year [2].

If you believe this change will place an undue burden on your staff, now might be a good time to investigate medical billing and coding companies that can offer specialized support.

4. Mental Health Billing Sees Changes
While specific changes in this space will vary, it’s important to keep an eye on the fact that across the board, the industry is seeing increased emphasis on mental and behavioral health services. This includes tele-behavioral health services, meaning many providers will or may already be expanding their service offerings in these spaces—an expansion that will complicate medical billing and coding services.

5. Physician Assistant Billing Expands
A change that’s been anticipated for a while, physician assistant billing is scheduled to change this year too. While they’ll still only be billed as mid-level providers at 85%, their services can now be billed directly, reassigned, or even incorporated with other physician assistants.

This shift can help address staffing challenges and expand care delivery options. But providers might face problems if they don’t fully understand Medicare guidelines and credentialing requirements.

Know that overall, these changes for 2022 can be significant, especially if a provider is taking the opportunity to expand or change services to take advantage of emerging opportunities. If you want to rethink your medical billing and coding services as a result, we encourage you to take some time with us to get the strongest start possible.

[1] K. B. O’Reilly, “Nearly 250 new CPT codes in store for 2022,” American Medical Association, 14 September 2021. Available:
[2] K. Pollitz, “No Surprises Act Implementation: What to Expect in 2022,” Kaiser Family Foundation, 10 December 2021. Available:

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