CMS Releases 2021 Proposed Medicare Physician Fee Schedule

September 4, 2020

On Monday August 3, 2020, the Centers for Medicare & Medicaid Services (CMS) released the 2021 proposed Medicare Physician Fee Schedule (MPFS), which includes proposed policy changes to the Quality Payment Program (QPP) for 2021 and beyond.

Medicare Physician Fee Schedule (MPFS)
With the budget neutrality adjustment to account for changes in RVUs, the proposed 2021 MPFS conversion factor is $32.2605, a 10.6% decrease from 2020’s $36.0896.

The separately calculated Anesthesia Conversion Factor is proposed at $19.9631, a 10.08% decrease from the 2020 conversion factor of $22.2016.

The significant decrease in the conversion factors is the result of CMS choosing 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. In order to maintain budget neutrality with these valuation increases, the proposed CY 2021 conversion factors are reduced.
CMS estimates an overall impact to allowed charges from MPFS proposed changes as follows:

  • Anesthesiology: -8%
  • Diagnostic Radiology: -11%
  • Interventional Radiology: -9%
  • Diagnostic Testing Facility: -6%
  • Emergency Medicine: -6%
  • Critical Care: -8%
  • Nuclear Medicine: -8%
  • Pathology: -9%
  • Radiation Oncology/Therapy Centers: -6%
  • Physician Assistants: +8%
  • Nurse Practitioners: +8%

A few highlights of the MPFS Proposed Rule include:

  • Appropriate Use (AUC)/Clinical Decision Support (CDS): CMS did not address the AUC/CDS mandate for all advanced diagnostic imaging services in the proposed rule.
  • Payment for E/M Services: CMS is moving forward with its proposal finalized in the 2020 MPFS final rule to adopt the new coding structure for the office/outpatient evaluation and management (E/M) codes.
  • Supervision of Diagnostic Tests by Certain Nonphysician Practitioners: CMS is proposing to permanently allow nurse practitioners (NPs), clinical nurse specialists
  • (CNSs), physician assistants (PAs) and certified nurse midwives (CNMs) to supervise the performance of diagnostic tests in addition to physicians.
  • Expand Telehealth Coverage: CMS is proposing the addition of several codes to the list of approved telehealth services. In addition, CMS is proposing to create a third temporary category of criteria for adding telehealth services during the public health emergency for (PHE) for the COVID-10 pandemic. These services would remain on the list through the calendar year in which the PHE ends. Codes proposed for this new category include home health care, emergency department visits, and psychological care.

Highlights of the Quality Payment Program (QPP):
2021 Proposed Performance Threshold and Performance Category Weights:

  • The performance threshold proposed to be 50 points.
  • The Quality performance category to be weighted at 40% (5% decrease from 2020).
  • The Cost performance category to be weighted at 20% (5% increase from 2020).
  • The Promoting Interoperability performance category to be weighted at 25% (no change from 2020).
  • The Improvement Activities performance category to be weighted at 15% (no change from 2020).

By law, the Cost and Quality performance categories must be equally weighted at 30% beginning in the 2022 performance period.

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