CMS Releases Proposed Rule for the 2020 Physician Fee Schedule

On July 29, 2019, the Centers for Medicare & Medicaid Services (CMS) issued a proposed rule that includes proposals to update payment policies, payment rates, and quality provisions for services furnished under the Medicare Physician Fee Schedule (PFS) on or after January1, 2020. CMS is requesting comments on the proposed rule by September 27, 2019, and a final rule is expected to be released in November. The proposed rule estimates a conversion factor (CF) of $36.09 which is a slight increase from the 2019 CF of $36.04. 

Of interest to all, is the CMS response to the CPT changes to new and established office-based Evaluation and Management Services (E/M). In the 2019 Proposed Rule, CMS had proposed to make significant changes to the payments associated with outpatient E/M codes but did not implement the changes in the Final Rule. As a result, the CPT Editorial Panel made structural changes to this code set which was reviewed at the April meeting of the RUC (AMA/Specialty Society Relative Value Update Committee). In the proposed rule, CMS accepted the RUC recommendations for work Relative Value Units (RVUs) and with minor changes the recommended practice expense inputs. CMS is also proposing reducing the documentation burden for office E/M services stating that provides can review and verify (sign/date) notes made by other physicians, residents, nurses, students or other members of the medical team rather than re-documenting this information. Of note, CMS did not apply the E/M value changes to the global surgical package. CMS continues to consider the elimination of the global package for services with a 010 or 090-day global period.

Of interest to pain medicine providers, are the proposed values for Somatic Nerve Injections (CPT codes 64400-64450). In May 2018, the CPT Editorial Panel approved the revision of descriptors and guidelines for the codes in this family and the deletion of three CPT codes to clarify reporting (i.e., separate reporting of imaging guidance, number of units and a change from a 0-day global to ZZZ for one of the CPT codes in this family). For 2020, CMS rejected the RUC recommended values for a number of these codes. AAPM, in conjunction with the AMA and other interested specialty societies, is preparing a response before the September deadline for comments.

For CY 2020, CMS is conducting the statutorily required 3-year review of the Geographic Practice Cost Indices (GPCIs) which are used in part to determine geographic adjustments made to the RVUs. This review happens to coincide with the statutorily required 5-year review of the Malpractice (MP) RVUs. Since there is common data used in these reviews, CMS is proposing that the review of the GPCI and the MP RVUs be aligned in the future. This would result in the next review for both factors in 2023.

CMS is also proposing the addition of telehealth codes which describe a bundled episode of care for treatment of opioid use disorders. CMS is also announcing a new Medicare Part B benefit for opioid use disorder (OUD) treatment services, including medications for medication-assisted treatment (MAT), furnished by opioid treatment programs (OTPs). Requirements for the OTPs are included in the Proposed Rule.

Other changes include revisions to the supervision requirements for Physician Assistants to allow increase flexibility, new HCPCS codes for select Chronic Care Management Services and increase payment for Transitional Care Management.

A fact sheet on the CY 2020 Physician Fee Schedule proposed rule is located here.

View the CY 2020 Physician Fee Schedule proposed rule.

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