2021 Medicare Physician Fee Schedule (PFS) Final Rule
December 1, 2020, the Centers for Medicare & Medicaid Services (CMS) released the 2021 Medicare Physician Fee Schedule (PFS) Final Rule, which includes final policy changes to the Quality Payment Program (QPP) for 2021.
CMS chose to move forward with adoption of the new coding structure for the office/outpatient evaluation and management (E/M) codes as recommended by the AMA, as well as the RUC-recommended values.
Conversion Factor
As expected and explained, in the August 2020 Proposed Medicare Rule summary, the significant decrease in the conversion factors is the result of CMS moving forward with the adoption of the new coding structure for the office/outpatient evaluation and management (E/M) codes. In order to maintain budget neutrality with these valuation increases, the Final 2021 conversion factors are significantly reduced.
As CMS did not address the negative reimbursement impact these E/M changes will have on many specialties, Congress must enact legislation if these provider cuts are to be averted.
Zotec Advocacy Efforts to Prevent Reimbursement Cuts
Zotec Partners has been actively lobbying on this issue for months. Since August, we have held numerous meetings, calls with elected officials and officials in the administration, as well as sent out a call to action, which generated 1000 advocates sending over 3100 emails.
On December 1, we sent out a call to action to urge Senators to cosign a letter to Senate leadership urging them to address the proposed deep Medicare cuts that are currently set to take effect on January 1, 2021. That letter goes to Senate leadership today, December 2.
There is still time to have your voice heard! Please go to Zotecpac.com and take immediate action.
CMS estimates an overall impact to allowed charges from MPFS final changes as follows:
Sequestration Cuts May Be Restored
In addition to the 2021 Medicare PFS schedule cuts noted above, the -2% sequestration reductions on Medicare expenditures across the board were delayed with the passage of the CARES Act in March 2020 but only until December 31. Without Congressional intervention during the “Lame Duck” Congress, each specialty noted above will incur additional cuts of -2% as of January 1, 2021.
Highlights of the MPFS Final Rule
Payment for Evaluation and Management (E/M) Services – Finalized for 2021:
Supervision of Diagnostic Tests by Certain Nonphysician Practitioners (NPPs)
Telehealth and Supervision
Due to the public health emergency (PHE), CMS adopted an Interim Final Policy to revise the definition of direct supervision to include virtual presence of the supervising physician or practitioner using audio/video real-time communication technology. CMS finalized their proposal to extend this policy through December 31, 2021 or the end of the calendar year in which the PHE ends, whichever is later.
PFS Payment for Services of Teaching Physicians – CMS is permanently extending a policy instituted during the COVID-19 PHE that allows teaching physicians to supervise residents remotely using telehealth (audio-visual) equipment.
Expanded Telehealth Coverage
CMS finalized their proposal to add 9 services to the Medicare telehealth services list on a Category 1 basis for 2021. CMS finalized their proposal to create a third category of criteria for adding services to the Medicare telehealth services list on a temporary basis:
2021 Quality Payment Program MIPS Value Pathways:
While CMS is moving forward with MIPS Value Pathways (MVPs) policy development, proposals for initial MVPs is delayed until at least the 2022 performance year.
Finalized MIPS Performance Thresholds and Category Weights Performance Thresholds:
Quality Data Completeness Requirements:
The data completeness requirement for quality measures remains at 70 percent. This number defines the minimum subset of patients within a measure denominator that must be reported.
2021 Category Weights:
By law, the Cost and Quality performance categories must become equally weighted at 30% by the 2022 performance period.
2021 Performance Period Scoring
2021 Quality Benchmarks:
In the Proposed Rule CMS stated they planned to use performance period benchmarks rather than historical benchmarks for the 2021 performance year out of concern that the COVID-19 PHE could skew benchmarking results.
Topped out Measures:
CMS will continue their methodology of capping measures at 7 points (out of a possible 10) if they have been topped out for two or more performance years but will adjust the score if the measure ceases to be topped out upon completion of data submission for the current performance year.
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