July 29, 2019
CMS Releases Proposed 2020 Medicare Physician Fee Schedule and Hospital Outpatient Rules
July 29, 2019—The American College of Cardiology (ACC) announced that the Centers for Medicare & Medicaid Services (CMS) released the proposed 2020 Medicare Physician Fee Schedule and the proposed 2020 Hospital Outpatient Prospective Payment System rule. Both will be published on August 15 in the Federal Register.
The ACC reported that under the Fee Schedule proposal, which addresses Medicare payment and quality provisions for physicians in 2020, there will be a virtually flat conversion factor on January 1, 2020, going from $36.04 to $36.09. CMS estimates that the physician rule will increase payments to cardiologists by 3% from 2019 to 2020 through updates to work, practice expense, and malpractice relative value units. This estimate is based on the entire cardiology profession and can vary widely depending on the mix of services provided in a practice, noted ACC.
ACC also advised that the outpatient payment rule indicates a 2.7% payment update for hospitals and other proposals. A “Medicare Hospital Outpatient Prospective Payment System and Ambulatory Surgical Center Payment System Proposed Rule (CMS-1717-P)” fact sheet is available on the CMS website here.
The ACC outlined the highlights of the proposed rules as follows:
Physician Fee Schedule
- After proposed changes to evaluation and management (E/M) payment were both altered and/or delayed until 2021 in the calendar year 2019 final rule last November, CMS proposes additional revisions to E/M documentation and payment policies.
- Walking back a previous plan to pay a blended rate for level 2 to 4 visits, CMS proposes to adopt revised E/M code definitions developed by the American Medical Association (AMA) Current Procedural Terminology editorial panel starting January 1, 2021. Members from across the House of Medicine worked together to find a way to respond to concerns about documentation burden in a manner that was less disruptive and correctly discerned differences in levels of E/M services.
- The proposal to adopt revised coding definitions is paired with a decision to pay for each level of service rather than utilize a blended rate.
- Incorporating recommendations from the AMA Relative Value Scale Update Committee, CMS proposes to adopt revised work and practice expense inputs for E/M services.
- CMS proposes no changes regarding implementation of the mandate requiring that clinicians consult appropriate use criteria through a qualified clinical decision support mechanism starting January 1, 2020, when ordering advanced imaging services.
- A request for information regarding changes that could be made to the Stark Law advisory opinion process.
- Updates to work and/or practice expense values for codes describing transcatheter aortic valve replacement, remote loop recorder interrogation and remote cardiac monitor interrogation, noncoronary intravascular ultrasound, and abdominal aortography. More details will be available after CMS posts supporting data tables.
- Proposed work and or practice expense values for new/revised codes describing self-measured blood pressure monitoring, ambulatory blood pressure monitoring, remote physiologic monitoring, pericardiocentesis and pericardial drainage, myocardial strain imaging, and myocardial positron-emission tomography.
2020 Quality Payment Program Performance Period
- Increase in the performance threshold from 30 points in 2019 to 45 points in 2020 and 60 points in 2021.
- Additional increase for exceptional performance to 80 points in 2020 and to 85 points in 2021.
- Revision of the performance category weights for quality to 40% in 2020, 35% in 2021, and 30% in 2022 performance year.
- Increase in cost performance category for cost to 20% in 2020, 25% in 2021, and 30% in 2022 performance year.
- Revision of the specifications for the total per capita cost and Medicare spending per beneficiary clinician measures (adding 10 new episode-based measures).
- Maintaining promoting interoperability and improvement activities at 25% and 15%, respectively.
- Maintaining performance-based scoring on individual measures under promoting interoperability performance category.
- Increase in the data completeness threshold for the quality data that clinicians submit.
- Increase in the threshold for clinicians who complete or participate in the improvement activity for group reporting.
- Updates to requirements for qualified clinical data registry measures and the services that third-party intermediaries must provide (beginning with the 2021 performance period).
- Application of a new merit-based incentive payment system (MIPS) value pathways (MVPs) framework to future proposals beginning with the 2021 MIPS performance year. MVPs would utilize sets of 106 measures and activities that incorporate a foundation of promoting interoperability and administrative claims-based population health measures and layered with specialty/condition-specific clinical quality measures to create both more uniformity and simplicity in measure reporting.
- Maintaining low-volume threshold, eligible clinician types, MIPS performance periods, certified electronic heath record technology requirements, and small practice bonus points.
Hospital Outpatient Rule
- A proposed requirement for hospitals to make public standard charge amounts for 300 “shoppable” services.
- Addition of codes describing angioplasty and stent PCI to the Ambulatory Surgery Center Covered Procedures list for calendar year 2020.
- Executing the second of a 2-year phase in to cap payment for off-campus hospital clinic visits at a rate equivalent to the physician fee schedule rate.
- The removal of one measure from the Hospital Outpatient Quality Reporting Program for the 2022 program year.