CMS has published the Proposed 2020 Medicare Physician Fee Schedule. The deadline for comment is September 27, 2019. The 1,704 page Proposed Rule contains a number of notable items including:
- Substantial revisions to the E/M overhaul scheduled for January 2021. The proposed revisions are intended to more closely align CMS and the AMA. This includes the proposal to allow separate payment, rather than a blended rate, for each E/M level, revision of service times, deletion of the extended visit add-on codes, and revise the primary and specialized care add-on codes. CMS also proposed to adopt the new E/M guideline instructions for use that have been issued by the AMA.
- Establishment of a general principle to allow physicians, PAs or APRNs who furnish and bill for their services to review and verify, rather than re-document, information in the medical record. The principle would apply to all Medicare-covered services and includes all entries made by physicians, residents, nurses, students and other members of the medical team.
- Revision of supervision requirements for PAs to allow coverage and meet requirements as long as services are performed within the state scope of practice and meet the supervision requirements prescribed by the state.
- Revision of ambulance provider/supplier certification requirements to redefine the list of staff who many sign certifications when a physician is unavailable and redefine medical necessity documentation requirements.
- Revision of therapy regulations pertaining to the therapy cap, use of the KX modifier and required use of modifiers for services rendered in whole or in part by a therapy assistant.
- The Proposal is also soliciting input regarding an advance beneficiary notification of coinsurance for screening colorectal exams.
The Proposed Rule includes many other important issues including opioid treatment programs, home infusions, cardiac rehab and payment revisions. We recommend you read the completed Proposed Rule to understand the changes and impact to your practice. We also recommend you begin preparing for the significant E/M changes that are scheduled to be implemented in just over a year.
The Proposed Fee Schedule is located at: https://www.cms.gov/Medicare/Medicare-Fee-for-Service-Payment/PhysicianFeeSched/PFS-Federal-Regulation-Notices-Items/CMS-1715-P.html
A summary of the AMA E/M changes for 2021 can be located at: https://www.ama-assn.org/practice-management/cpt/cpt-evaluation-and-management