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CMS Issues Final Rule for Physician Fee Schedule for 2020

The Centers for Medicare & Medicaid Services (CMS) issued its Final Rule for 2020 that that includes proposals to update payment policies, payment rates, and quality provisions for services furnished under the Medicare Physician Fee Schedule (PFS). As proposed, the 2020 PFS conversion factor is $36.09 which is $0.05 above the 2019 conversion factor. The conversion factor is multiplied by the total adjusted Relative Value Units (RVUs) to achieve a payment amount for the services included in the Medicare Physician Fee Schedule.

 The Final Rule also addresses public comments submitted in response to the Proposed Rule released in July. AAPM provided written comments to several areas of importance to Pain Medicine physicians that were outlined in the September 25 AAPM E-News.

AAPM specifically addressed the practice expense inputs for the new genicular injection and RFA codes (codes 64624 and 64454). CMS had proposed a decrease in the AMA/Specialty Society Relative Value Update Committee (RUC) recommended practice expense inputs for these services. The Proposed Rule included only one cannula and one RF kit for code 64624. After consideration of comments submitted by AAPM and others, CMS agreed to increase the number of cannula and kits from one to three. This change also resulted in acceptance of the RUC recommended equipment time which was also decreased in the Proposed Rule. AAPM also opposed the CMS change to the recommended work RVUs (wRVU) for the RFA code. Unfortunately, CMS did not accept the submitted comments, therefore the wRVU for code 64624 (Destruction by neurolytic agent genicular nerve branches including imaging guidance, when performed) will be 2.50 rather than 2.62 as recommended by the RUC.

Similarly, CMS proposed decreases in the practice expense inputs for the new codes for sacroiliac injection and RFA (codes 64451 and 646250. The Final Rule considered the AAPM submitted comments and increased the number of spinal needles included in the PE from 3 to 4 and accepted the RUC recommended equipment time for these services.

AAPM and other societies responded to the CMS proposal to decrease the RUC recommended wRVUs for many of codes in the revised family of somatic nerve injections. Despite the comments and rationales provided by several societies, CMS is maintaining the wRVUs as outlined in the July Proposed Rule.

Of other interest, CMS confirmed its plan to align its E/M coding with changes adopted by the American Medical Association (AMA) Current Procedural Terminology (CPT) Editorial Panel for office/outpatient E/M visits. Further, it accepted the RUC recommended work values for these services. These changes will not be incorporated until 2021.

CMS is also finalizing broad modifications to its documentation policy so that physicians, physician assistants, and advanced practice registered nurses can review and verify (sign and date), rather than re-documenting, notes made in the medical record by other physicians, residents, physician assistants, and APRN students, nurses, or other members of the medical team.

AAPM is hosting a webinar that will review these areas and other important payment policies that impact Pain Medicine practices, as well as a review of the CPT and ICD-10 changes for 2020. The webinar "Preparing for 2020: Update on Coding and CMS Policy Changes" will be held on December 11 at 2-3PM CT. Registration information can be found here.

The CMS fact sheet on the Final Rule can be accessed here. The complete Final Rule can be accessed here.

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