Change is in the air: A Review of the 2020 Physician Fee Schedule

The Centers for Medicare and Medicaid Services releases Physician Fee Schedules annually, but 2020 is a year that comes with great change. In a few weeks, 2020 will reflect an Administration-wide emphasis on maximizing healthcare accessibility, driving quality, and increasing affordability while encouraging innovation. Additionally, the new fee schedule will enable a wide variety of providers, practitioners, and entities to provide services as a method of team-based care and hopefully help the entire healthcare industry prepare for value-based contracting.

I wanted to highlight a few aspects that drew my attention:

  1. Documentation: Documentation is getting a bit of an overhaul for primary care services. Evaluation and Management services (E&M) have been scrutinized for years for requiring too much documentation for the reimbursement amount. To decrease documentation burden, CMS has aligned with the American Medical Association Current Procedural Terminology (AMA CPT) guidelines to achieve the following:
    1. Deleting the 99201 code for new patients, while keeping the 99211 for established patients.
    2. Assigned separate payments, rather than blended rates, for 99202-99215 CPT codes, the level of a visit is based on clinical decision making or time, which will provide clinicians with appropriate reimbursement, more time spent with a patient result sin increased payment.
    3. For extended or prolonged visits, you can add a G code of GPC1X to the 99 codes, to be implemented in 2021, which will provide increased reimbursements for additional time spent providing care.
  • Care management services: Existing Transition Care Management (TCM) and Chronic Care Management (CCM) are favored services in delivering value-based care and a new CPT has been introduced, Principal Care Management (PCM) for those with one chronic condition.  In order to not disrupt too much, a few G codes have been added to assist with coding.
    • TCM- Higher payment rates have been approved for 99495 and 99496.
    • CCM- For non-complex CCM, CMS is using 99490 with a new G code of G2058.
    • PCM- Because CCM requires patients to have 2 or more chronic conditions, the PCM was created for additional care provided to patients with at least one chronic condition. The codes are G codes: G2064 and G2065.
    • Telehealth: CMS did add a new CPT code, 99458, to pay for remote patient monitoring and interpretation of digitally collected data with 99457 and 99458 covering 20-minute intervals of remote services. In 2020, the two CPT codes will be billable under general supervision, which will provide more room for team-based care.
  • Opioid management: Specific codes for therapy and treatment have been introduced to further aid in opioid use and disorder treatments.
    • CMS is approving of new Medicare Part B medications for medication-assisted treatment furnished by opioid treatment programs.
    • CMS is finalizing a zero copay for beneficiaries in 2020 undergoing approved opioid treatment.
    • Bundled payment rates are being determined and established as well as approved drug components of the bundles.
    • Physician Therapy and Occupational Therapy modifiers have been established for the therapy provided.
  • MSSP quality reporting: CMS is aligning the MSSP more closely with MIPS to reduce the burden on resources.
    • ACO 43, which is the Ambulatory Sensitive Condition Acute Composite Score, will be pay-for-reporting for performance years 2020 and 2021 because of a substantive change.
    • A change to ACO 17 for tobacco screening will be made for 2020 but will remain as-is for 2019.
    • There will be a total of 23 measures for ACOs to report during the Group Practice Reporting Option (GPRO).

With these changes coming down the pipeline it becomes so incredibly important to be up-to-date for proper reimbursement both on a fee-for-service basis for services rendered as well as on the quality metric reporting front. The movement to risk will be resource-intensive but should lean towards changes that promote interoperability, decrease burden, and further outcome-based care.

Amy Kotch

About the Author

Amy Kotch, MHA

Amy Kotch is Salient’s Lead Business Consultant working with ACOs nationwide. She received a masters in health administration from Florida Atlantic University as well as a bachelors of science from the University of Miami and has just recently completed a master certification in population health through a federal grant from the Office of the National Coordinator for Health Information Technology in conjunction with the Johns Hopkins University and Normandale Community College. Her prior work includes being the operations coordinator at Triple Aim Development Group consulting with ACOs/MSOs.

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