On July 29, the Centers for Medicare & Medicaid Services (CMS) released the DRAFT CY 2020 Medicare Physician Fee Schedule (MPFS). Overall, the A/I specialty is not expected to see a decrease in its total Medicare revenues, and the conversion factor – the value used to calculate total relative value units (RVUs) into payment rates - is up slightly at $36.0896. The AAAAI, with our expert consultants at Hart Health Strategies, continues to analyze the proposals. We will be sharing additional information soon, and will post our comments to be submitted to CMS in September.
Click here to compare 2020 proposed reimbursement for allergy codes with 2019 reimbursement values. To review how CMS converts RVUs into compensation, click here. To review CMS’ draft Evaluation and Management (E/M) code proposal from the 2020 proposed rule, click here.
Key provisions of interest to the A/I community are highlighted below.
Evaluation and Management (E/M) Coding and Payment. Stepping back from its previously announced policies, CMS proposes to align its E/M coding policies consistent with recommendations by the AMA CPT Editorial Panel, and accept the associated AMA RUC recommended values. If finalized and implemented in CY 2021, CMS anticipates a 7% increase to A/I. To review the proposed new Evaluation and Management (E/M) codes click here.
Review and Verification of Medical Record Documentation. Last year, CMS finalized that a teaching physician could review and verify (sign/date) notes made by a medical student in a patient’s medical record for E/M services, rather than having to redocument the information. Given concerns raised by non-physician practitioners, CMS proposes to establish a general principle to allow the physician, the PA, or the APRN who furnishes and bills for their professional services to review and verify, rather than re-document, information included in the medical record by physicians, residents, nurses, students or other members of the medical team.
Care Management Services. CMS proposes to revise its billing requirements for transitional care management (TCM) services by allowing TCM codes to be billed concurrently with other key services, including prolong services without direct patient contact, complex chronic care management (CCM) services, and care plan oversight services. CMS also proposed to increase the work RVUs for certain TCM services, resulting in higher reimbursement when these services are delivered. CMS anticipates that this will lead to increased access to TCM services by Medicare beneficiaries. With regard to CMM services, CMS proposes to adopt two new G-codes for complex CCM services, as well as two new G-codes for non-complex CCM. These codes are anticipated to be replaced once the AMA CPT Editorial Panel completes revisions associated with these services. Last, CMS proposes two new codes for principal care management (PCM) services, which describe care management services for one serious chronic condition, and would be predominantly billed by specialists who are focused on managing patients with a single complex chronic condition requiring substantial care management.
Communication Technology-Based Services (CTBS). Last year, CMS finalized new codes and payment for CTBS (i.e., virtual check-in, evaluation of store and forward images, and interprofessional internet consultation). Hearing concerns that obtaining beneficiary consent for each discrete service is burdensome, CMS proposes that practices could use a single advance beneficiary consent.
Merit-based Incentive Payment System (MIPS). CMS proposes significant changes in the MIPS program, including an increase in the Cost performance category weight (from 15% to 20%) with a corresponding decrease in the Quality performance category weight (from 45% to 40%). With regard to quality measures, CMS is proposing to add a new quality measure – Adult Immunization Status – to the A/I specialty set, and remove the following measures – Influenza Immunization, Pneumococcal Vaccination Status for Older Adults, and Pneumocystis Jiroveci Pneumonia (PCP) Prophylaxis. AAAAI has advocated for the removal of other HIV/AIDS measures from the specialty set, and will continue to press for this revision in our formal comments. As a reminder, the AAAAI QCDR contains the most relevant measures for A/I practices, and captures other key data helpful to our efforts in demonstrating the safety of in-office compounding of allergenic extracts.
CMS also proposes modifications to the Qualified Clinical Data Registry (QCDR) measure standards for MIPS, which will require measure testing, harmonization, and clinician feedback. Given AAAAI’s considerable investment, we will work diligently to ensure requirements are reasonable, that our QCDR is compliant, and will continue to be available for A/I practices to use for MIPS and other research activities.
Finally, CMS requests information on a proposed framework for new MIPS Value Pathways (MVP), aimed at streamlining the MIPS program and making it more clinically relevant. While a potentially positive development that could assist A/I practices, CMS intends to employ administrative claims-based measures focused on population health, which may not be relevant to A/I practices and patients. AAAAI will work with the medical community on a coordinated response to ensure the new MVP can be a success.
Open Payments. As required by law, CMS proposes to include non-physician practitioners as “covered recipients” in its Open Payments program. This means PAs, NPs, CNSs, CRNAs, and CNMs would have data reported about their payments from industry in the Open Payments system. CMS also proposes to modify the nature of payment categories by consolidating separate distinctions for payments made to faculty at accredited/certified and unaccredited/non-certified continuing education programs into one “medical education programs” category, and establishing categories for debt forgiveness, long-term medical supply or device loan, and acquisitions.
AAAAI will continue to analyze the proposals and provide additional information soon. If you have questions or would like to flag key concerns about these proposals as they relate to your practice, we welcome your feedback at firstname.lastname@example.org.