The Centers for Medicare and Medicaid Services (CMS) recently released a 1700-page proposed rule for the 2020 Medicare physician fee schedule. The rule covers diverse topics, including geographic payment adjustments and major evaluation and management (E/M) payment changes,  as well as new payments for managing patients with opioid use disorder. Below is an overview of some key topics included in the proposed rule. 

Office Visits – Evaluation and Management

The American Medical Association (AMA), California Medical Association (CMA) and others in organized medicine worked in partnership with CMS to significantly modify the office visit policy included in the proposed rule. While retaining the important modifications to reduce documentation burden, CMS will implement coding and payment modifications in 2021 that are based on the resources required to perform various levels of office visits. This will ensure that physicians treating the sickest patients are not unfairly penalized, while providing simpler solutions to coding and documentation.

We are very pleased that CMS has largely accepted the AMA CPT and the AMA/Specialty Society RVS Update Committee framework and recommendations proposed by the AMA-convened workgroup. Two aspects of the CMS proposal depart from these recommendations, however, and exacerbate the negative payment impacts from this policy change on physicians in certain specialties. CMA and AMA will be working to address these issues through the comment process.

Click here to view a table (111) of the specialty payment impacts if CMS finalizes the proposal without modification. Redistributions will be significant, with family medicine increasing by 12% and many specialties that do not perform office visits decreasing by 7% or more. Click here to view another table (115) that reflects impacts if CMS does not implement the new add-on code, showing a 7% increase to family medicine and cuts of -5% to specialties that do not perform office visits. Both impact tables should be viewed with caution as we believe they contain some errors. 

The proposed rule also includes the final cycle of the California geographic payment updates.

Additional highlights from the proposed rule are below:

• Conversion Factor: The conversion factor is slightly higher at 36.09, up from 36.04 from last year. Although we are in the MACRA payment freeze timeframe, CMA and AMA are continuing to urge Congress to fund a Medicare physician payment update with the savings from the Medicare prescription drug reform legislation.
• Telehealth: There are several new Telehealth G codes eligible for payment.

• Medication Assisted Treatments for Opioid Use Disorders: Last year, federal legislation authorized Medicare payment for certain opioid  use disorder treatment and medication assisted treatments. Those new payment rates and services are outlined in the proposed rule, including bundled payments.
• MIPS: There are numerous changes to the MACRA MIPS Quality Payment Program requirements but none of them appear to be significantly less burdensome. 
• Hospital Price Transparency: The proposal includes significant price transparency requirements on hospitals, with large penalties for noncompliance. Hospitals will be required to publicly disclose the standard payments they negotiate with insurers.

See also: “CMA to host webinar on Medicare changes for 2020.”