CMS proposes changes to physician fee schedule, quality payment program

The Centers for Medicare & Medicaid Services (CMS) is proposing changes to the Medicare Physician Fee Schedule (PFS) and the Quality Payment Program as part of its effort to reduce provider burden.

“Clinicians are drowning in paperwork and reporting requirements caused by cumbersome government rules and regulations,” said CMS Administrator Seema Verma in a press release. “These administrative costs add to the total cost of delivering healthcare, which means physicians often have to hire extra staff and spend more time complying with requirements instead of with their patients.”

The proposed changes for 2020 are as follows:

The PFS conversion factor for RVUs would increase from $36.04 to $36.09, and three codes would be added for telehealth services that treat opioid abuse disorders.

In addition, CMS is proposing that CPT coding retains five levels of coding for established patients, reduces the number of levels to four for office/outpatient E/M visits for new patients and revises the code definitions.

The proposed CPT changes also revise the times and medical decision-making process for all of the codes and requires performance history and exam only as medically appropriate. In addition, the changes would allow clinicians to choose the E/M visit level based on either medical decision-making or time.

CMS is proposing to adopt the AMA Relative Value Scale Update Committee’s recommended values for the office/outpatient E/M visit codes for 2021 and the new add-on CPT code for prolonged service time. The recommended values would increase payments for office/outpatient E/M visits.

Also under consideration is consolidating the Medicare-specific add-on code for office/outpatient E/M visits for primary care and non-procedural specialty care that was finalized in the 2019 PFS final rule for implementation in 2021. These will be consoldated into a single code describing the work associated with visits that are part of ongoing care related to a chronic condition.

Additional proposals include:

• Changing the physician supervision requirements for Physician Assistants. In the absence of state law governing physician supervision of PA services, the physician supervision required by Medicare for PA services would be evidenced by documenting in the medical record the PA’s approach to working with physicians in furnishing their services.
• Changing verification process of medical records. Physicians, PAs, NPs, clinical nurse specialists and certified nurse-midwives could review and sign, rather than re-documenting, notes made in the medical record by other physicians, residents, nurses, students or other members of the medical team.
• Increasing payment for Transitional Care Management. Also, certain Chronic Care Management services would receive Medicare-developed HCPCS G codes. Clinicians could bill incrementally to reflect additional time and resources required in certain cases

CMS is also proposing changes to streamline the Quality Payment Program. Beginning in the 2021 performance period a new framework, the MIPS Value Pathways, would move MIPS from its current requirement that clinicians report on quality, cost, interoperability and improvement categories, to a system where they would report on a smaller set of measures. These measures would be specialty-specific, outcome-based and more closely aligned to Alternative Payment Models. CMS would also provide more data and feedback to clinicians to help them improve their performance.

Public comments to the proposed rules are due by September 27. To view all the proposed changes, click here.