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CMS Issues CY 2020 Physician Fee Schedule Proposed Rule

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The Centers for Medicare & Medicaid Services (CMS) has issued its proposed rule updating the Medicare physician fee schedule (PFS), quality payment program, and other Medicare Part B payment policies for calendar year (CY) 2020. Comments on the proposed rule are due Sept. 27. Key provisions of the proposed rule are highlighted below:

  • Evaluation and Management (E/M) Services: In a change from its policies finalized for the CY 2019 PFS, CMS proposes to revert back to setting separate payment rates for all levels of E/M visits rather than blending payment rates for certain levels. Specifically, CMS would retain five levels of coding for established patients, reduce the number of levels to four for new patients, and allow providers to choose the E/M level based on either medical decision-making or time. In addition, for CY 2021, CMS would adopt a new add-on code for prolonged service time and consolidate previously finalized add-on codes for primary care and non-procedural specialty care.
  • Medicare Coverage for Opioid Use Disorder Treatment Service: CMS proposes policies to implement requirements of the SUPPORT Act to establish 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).
  • Bundled Payments for Substance Use Disorder Services: CMS proposes to create new coding and payment for a bundled episode of care for management and counseling for OUD.  The proposed codes describe a monthly bundle of services for the treatment of OUD that includes overall management, care coordination, individual and group psychotherapy, and substance use counseling. CMS also seeks comment on bundles describing services for other SUDs and on the use of MAT in the emergency department setting to inform future rulemaking.
  • Telehealth Services: CMS proposes to add three HCPCS codes that describe a bundled episode of care for treatment of opioid use disorders to the list of available telehealth services.
  • Case Management Services: CMS proposes several policies related to care management services, including increasing payment and billing flexibility for care management provided to beneficiaries after discharge from inpatient and certain outpatient stays. CMS also proposes changes to improve the accuracy of payment for chronic care management services and reduce burden associated with billing for these services, and to introduce new coding and payment for care management services for patients with a single serious chronic condition.
  • Therapy Services: CMS proposes policies to implement mandated therapy modifiers — as finalized in the CY 2019 PFS final rule — that identify therapy services furnished in whole or in part by physical therapy and occupational therapy assistants. Beginning with services furnished in 2022, these services are paid at a reduced level; CMS clarifies that this does not apply to services furnished by critical access hospitals because they are not paid for therapy services at PFS rates.
  • Medicare Shared Savings Program: CMS proposes changes to the Medicare Shared Savings Program quality reporting requirements, and seeks comment on how to better align the quality performance scoring methodology more closely with the Merit-based Incentive Payment System (MIPS) quality performance scoring methodology.
  • Quality Payment Program: CMS proposes changes to the physician Quality Payment Program, including updates to the MIPS for the CY 2020 reporting period, such as a higher weight on cost measures, and higher performance standards for earning positive payment adjustments. CMS also proposes policies related to incentives for alternative payment model participation.

CHA will provide members with a more detailed summary of the proposed rule in the coming weeks. Additional information is available in a CMS fact sheet and a separate Quality Payment Program fact sheet.