2020 Medicare Final Rules

Late Friday, CMS published both the Final 2020 Medicare Outpatient Prospective Payment Rule and the Final 2020 Medicare Physician Fee Schedule. The preponderance of the documentation, coding and billing changes are scheduled to occur on January 1, 2020.  Providers need to identify the changes that are relevant to their practices and begin preparing critical system updates, as well as, policy and procedure revisions and educating their staff.  We also strongly recommend providers start preparing now for the massive E/M changes which will be effective January 1, 2021.    

The HBE team of compliance, coding and billing experts are ready to assist you with identifying and implementing the new guidelines to ensure your organization’s financial and compliance success.  Key highlights from the Final Rules are as follows:

Proposed Change Final Rule
Establishment of a 1-year exemption from patient status denials and referrals to RACs for procedures that are removed from the inpatient Finalized- The final rule extends the exemption to 2 years rather than 1.
Removal of total hip arthroplasty (THA) from the inpatient only list Finalized-  CPT 27130 (THA) was removed as well as 6 spinal procedures and 5 anesthesia codes
Updated requirements for hospital charge transparency to mandate hospitals post standard charges in two separate, searchable “consumer-friendly” ways with penalties for non-compliance Postponed-  CMS will provide a response in a forthcoming rule.
Adoption of the physician fee schedule payment rates for clinic visit services provided in excepted off-campus provider-based departments Finalized
No changes to payment status indicators Finalized
No changes to quality measures Finalized
Proposed Change Final Rule
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 Finalized- CMS also indicated they are considering expanding the E/M changes beyond outpatient/office.
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 Finalized
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 Finalized
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 Finalized
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. Finalized

The Final OPPS Rule is here: https://s3.amazonaws.com/public-inspection.federalregister.gov/2019-24138.pdf

The Final Physician Fee Schedule is here:  https://s3.amazonaws.com/public-inspection.federalregister.gov/2019-24086.pdf

A summary of the AMA E/M changes for 2021 can be located here:  https://www.ama-assn.org/practice-management/cpt/cpt-evaluation-and-management

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