On Friday December 1st 2020, CMS released the final Physician Fee Schedule (PFS) slated to take effect on January 1, 2021.
First proposed in August of 2020 along with a public comment period, the final rule is being released about one month later than normal due to the current COVID public health emergency or PHE.
Unfortunately, despite the delayed release, the final rule still goes into effect on January 1st 2021 leaving only one month for providers and provider advocate groups like the AMA and ACOs to petition congress for changes and relief, especially to the reduced Conversion Rate Factor of approximately 10% (read below for more)
In addition to updates to the payment and quality policies and programs the final rule includes important and meaningful changes to a broad range of services: ACO's, telehealth/telemedicine and regulatory waivers related to the current COVID national health emergency.
Coming in at over 2100 pages the 2021 Final Rule is a comprehensive and massive document. To read CMS's summary fact sheet you can click here.
In order to save you some time we've written the following blog post to summarize the most salient points.
Top Takeaways From the CMS 2021 Final Rule
Office Visit Payment Increases
Starting January 1st 2021 CMS will begin implementing their new E/M coding, documentation and payment system as we previously detailed in an earlier blog post. In 2021 providers will benefit from simplified documentation of office visits and receive significantly higher reimbursements. In 2021 providers will choose the level of E/M code based on either the time spent with the patient, the non face to face time spent preparing for the visit and the non face to face time spent after the patient leaves reviewing results, coordinating care etc. OR the medical decision making or MDM. The history and physical "bullet points" will no longer count towards the E/M code - you still need to do a medically appropriate H&P but now it can be a more narrative description rather than structured data picked from a list. The resulting changes will result in increased reimbursements of over 10% for E/M visits as well as new codes and reimbursement for complex and prolonged visits
Conversion Factor Decrease
However due to a law enacted by Congress changes to the PFS must be budget neutral. Therefore the increases in the E/M visits must be offset resulting in a 10% reduction in the conversion factor across the board. A decrease $3.68 from the 2020 PFS conversion factor of $36.09 to $32.41. Surgical providers and other specialists who don't bill E/M codes will see a significant drop as a result. Many providers and provider advocacy groups oppose these cuts. Failing to stop the proposed PFS from becoming final they are now lobbying congress to stop the cuts from becoming effective.
CMS Finalizes Telehealth Expansion and Improving Rural Health
Stating that they are now finalizing a permanent expansion of Medicare telehealth services including home health visits, behavioral health, prolonged visits and more complex visits. The following list of services has been added on a Category 1 basis:
- Group Psychotherapy (CPT code 90853)
- Psychological and Neuropsychological Testing (CPT code 96121)
- Domiciliary, Rest Home, or Custodial Care services, Established patients (CPT codes 99334-99335)
- Home Visits, Established Patient (CPT codes 99347-99348)
- Cognitive Assessment and Care Planning Services (CPT code 99483)
- Visit Complexity Inherent to Certain Office/Outpatient Evaluation and Management (E/M) (HCPCS code G2211)
- Prolonged Services (HCPCS code G2212)
Minor Changes to MIPS
Stating that they don't want to overburden providers as they continue to deal with the pandemic CMS is limiting the number of significant changes to the Quality Payment Program in 2021. The following changes will be made to the Merit Based Incentive Payment System or MIPS program:
- An increase in the overall scoring performance threshold from 45 to 60 points
- A decrease in the quality performance category to be weighted at 40% (down from 45% in 2020)
- An increase in the cost performance category to be weighted at 20% (up from 15% in 2020)
- The Promoting Interoperability category weighting stays at 25%
- The Improvement Activities performance category also stays at 15%.
Due to the pandemic CMS will also delay the initial transition to the MIPS Value Pathways (MVPs) participation framework until at least 2022.
Click here to read the CMS 2021 Final Rule Fact Sheet
Click here to read the CMS Telehealth Changes Fact Sheet
Finally, if you're looking to upgrade or change your current EHR to the top rated cloud based EHR in 2021 please click the button below to learn more about how NextGen Office EHR/PM can help your practice deal with the new E/M coding guidelines.
