CMS Proposed Physician Fee Schedule 2021

CMS has issued the proposed physician fee schedule for 2021 for review and comment. There are several elements that will have a significant impact. Most importantly, a proposed adjustment downwards of the conversion factor to maintain budget neutrality while increasing  reimbursement to primary care. There are some changes to Telehealth & E/M coding and an extension of the testing period for Appropriate Use Criteria (AUC).

Conversion Factor: This is the value assigned per RVU (relative value unit). Each CPT code is assigned a specific number of RVUs, and therefore the conversion factor directly impacts reimbursement. The proposed change from $32.36 v. $36.09 in the current fee schedule is a net reduction of $3.83/RVU. The impact to your practice is listed below.

• Anesthesiology              -8%
• Cardiology                     +1%
• Family Practice             +13%
• Internal Medicine          +4%
• Pathology                       -9%
• Radiology                       -6% to -11%  
• Diagnostic -11%
• Interventional -9%
• Nuclear Medicine -8%
• Radiation Oncology & Therapy -6%

AUC: CMS has extended the testing period for this program through 2021. Payment for claims will not be impacted.  However, we recommend that providers use this additional time to prepare.

E/M Proposed Changes:

• Removal of new patient level 1 visit, 99201
• Increased RVUs for E/M services
• Making a modification to the framework from the use of history and exam to medical decision making or total time spent with the patient. This compliments the documentation changes already approved in the final rule for 2020 and set to begin in 2021.

Medicare Telehealth Services:

• Adding 9 services permanently
• Adding 13 services temporarily. This is in response to the COVID-19 PHE & they will extend to the end of the calendar year in which the COVID-19 PHE ends.

This is only a proposed rule. The comment period is open until 10/05/2020, and anyone can add a comment. Several professional organizations will be making comments on behalf of their providers. You may add your individual comment on the regulations page, and click "Comment" on the top left  side of the page. To see more detailed information on this and additional QPP changes, you can find the complete rule here.