While the AAFP conducts a thorough review of the proposed rule(www.federalregister.gov) for the 2020 Medicare physician fee schedule and Quality Payment Program that CMS released July 29, members can turn to an initial summary(4 page PDF) the Academy created to highlight points of key interest to family physicians.
In addition, CMS has published a fact sheet(www.cms.gov) on the proposed fee schedule changes, along with a 28-page document(qpp-cm-prod-content.s3.amazonaws.com) summarizing proposed QPP changes.
Also on July 29, the agency released the proposed rule(www.federalregister.gov) for the 2020 Hospital Outpatient Prospective Payment System, which would require hospitals to publicly report their gross charges and payer-specific negotiated charges while continuing to phase in site-neutrality provisions and expand the list of services that can be provided in an outpatient setting.
The Academy is preparing detailed formal comments on both rules ahead of the Sept. 27 deadline. Several elements of the MPFS proposed rule that already are of obvious note to the AAFP are outlined below.
2020 Medicare Physician Payment
The 2020 proposal would increase the Medicare conversion factor slightly, from $36.04 to $36.09.
The proposed rule also aims to simplify coding and billing for office-based evaluation and management services. Specifically, starting in 2021, it would align E/M coding with changes laid out by the CPT Editorial Panel for office/outpatient E/M visits by
- retaining five levels of coding for established patients,
- setting only four levels for office and outpatient E/M visits for new patients,
- revising the times and medical decision-making process for all office-based E/M codes and requiring performance of history and exam only as medically appropriate, and
- allowing clinicians to choose the E/M visit level based on either medical decision-making or time.
Additionally, the proposed rule would pay clinicians for the time they spend managing patients with greater needs and create new coding to compensate clinicians for providing care management to patients with a single serious or high-risk condition.
The proposed fee schedule does not alter total Medicare allowed charges for family medicine in 2020, but CMS estimates that total allowed charges for family medicine would increase 12% in 2021. (The Academy's summary includes reference tables comparing allowed specialty charges.)
Quality Payment Program Changes
For the QPP's Merit-based Incentive Payment System, CMS proposes to
- increase the performance threshold (i.e., the minimum number of points required to avoid a negative payment adjustment) to 45 in 2020 and 60 in 2021;
- increase the additional performance threshold for exceptional performance to 80 points in 2020 and 85 points in 2021;
- reduce the quality performance category weight to 40% in 2020, 35% in 2021 and 30% in 2022; and
- increase the cost performance category weight to 20% in 2020, 25% in 2021 and 30% in 2022.
CMS also would create MIPS Value Pathways starting in the 2021 performance period. The Academy's summary notes that these MVPs would allow clinicians to report using a smaller set of measures that are "specialty-specific, outcome-based and more closely aligned to alternative payment models."
Opioid Treatment Coverage
Under the proposed rule, Medicare would cover medication-assisted treatment for patients with opioid use disorder in treatment programs accredited by the Substance Abuse and Mental Health Services Administration.
The rule also would create a new monthly bundled clinician payment for management and counseling involving MAT for such patients. This bundled payment would cover care activities such as overall patient management, care coordination, individual and group psychotherapy, and counseling. The Academy notes that this move would increase patient access to evidence-based services that support OUD recovery.
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