Proposed 2020 Medicare Fee Schedule Rule Released

The Centers for Medicare & Medicaid Services (CMS) recently released the calendar year 2020 Medicare Physician Fee Schedule (PFS) proposed rule. The draft rule includes a number of proposed changes to Medicare payment policy, rates, and quality program metrics. These include:
  • New Codes for Bundled Episodes of Care for the Treatment of Opioid Use Disorders
  • Changes to E/M Coding:
    • Retaining 5 Levels of Coding for Established Patients
    • Reducing to 4 Levels of Coding for New Patients and Revising Definitions
    • Revising Times and Medical Decision Making for All E/M Codes
    • Allowing Physicians to Select E/M Level Based on Time or Medical Decision Making
  • Modifying PA Supervision Requirements to Allow For Document Solely in the Medical Record, Unless More Restrictive State Law Exists
  • Modifying Medical Record Document Criteria to Allow for Review and Sign Instead of Redocumenting Notes from Other Members of the Care Team
  • New Chronic Care Management Codes to Allow Physicians to Bill Incrementally for the Additional Time and Resources Necessary to Manage Complex Patients
  • New Principal Care Management Codes for Care Management of Patients with a Single Serious and High Risk Condition
  • Additional Coverage and Bundled Payment for Opioid Use Disorder Treatment, Including Medication Assisted Treatment and Greater Flexibility for Services Rendered via Telemedicine
  • Soliciting Comments on How to Better Align the Medicare Shared Savings Program and the Merit-Based Incentive Payment System (MIPS) Performance Scoring Methodology
  • Adjustments to the CF 2017 Geographic Practice Cost Index (GPCI)
    • Elimination of the 1.0 Physician Work (PW) GPCI Floor to Reflect Expiration of the Temporary Statutory Floor at the End of 2019
    • Adjustments to the PW GPCI Continuing to Utilize Salary Data from Seven Occupational Categories on the Bureau of Labor Statistics (BLS) Occupational Employment Statistics (OES) 2014-2017 Survey as a Proxy for Physician Wage Data
    • Adjustments to the Practice Expense GPCI Continuing to Utilize BLS OES data and Residential Rent 2013-2017 Estimates from the American Community Survey as a Proxy for Physician Office Rent Data

IMS is continuing to evaluate the proposed rule and will be filing written comments. While several of the policy and payment changes put forward represent improvements in 2020, including a reduction in documentation burden and less severe changes proposed to E/M coding procedures, some provisions are cause for concern. This includes the ongoing issues with the GPCI calculations. Under the proposed rule – with loss of the 1.0 PW GPCI Floor and adjustments to the PW, PE, and Malpractice GPCIs – Iowa physician practices stand to lose approximately $22.5 million in Medicare payments. Watch futured IMS publications for additional information on the proposed rules.

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