Call to Comment on Proposed 2021 MPFS Fee Schedule Before October 5

SEPTEMBER 2020

Call to Comment on Proposed 2021 MPFS Fee Schedule Before October 5

Comments on the proposed 2021 Physician Fee Schedule (PFS) may be made until October 5 in anticipation of the final rule’s publication around December 1. Members of the pulmonary, critical care, and sleep medicine community will want to pay special attention in providing input on two areas in the release from The Centers for Medicare and Medicaid Services (CMS): (1) the drop in the conversion factor; and (2) the acceptance of changes to office evaluation and management (E/M) Current Procedural Terminology (CPT®) codes. (See complete code list in the September 2020 issue  of CHEST Physician.)

Legislated budget neutrality requires that increased spending in any area be offset by reductions in other areas. Significant in the 2021 proposal is that, unlike previous years, the change in the PFS conversion factor for one relative value unit (RVU) for reimbursement will go down 10.61% from $36.09 to $32.26 to accommodate increases in the RVUs related to the revaluing of the office E/M CPT codes and other programs and services. A greater reduction in reimbursement will occur in those specialty practices with more inpatient and procedural services, while office-based practices will see an increase in reimbursement. For example, the proposed change in 2021 reimbursement for family practice results in a 13% increase, while it is an 8% decrease for critical care medicine. (See “Joint Response Regarding 2021 Medicare Physician Fee Schedule for Critical Care” in this issue.) The increase in reimbursement for office E/M visits did not apply to visits bundled into global surgery codes, explaining the reduction in thoracic surgery and cardiac surgery of 8% and 9%, respectively.

CMS accepted the change in code descriptors and levels of reimbursement for office-based E/M codes 99202-99215 as recommended by the Relative Value Scale Update Committee (RUC), which are now determined based on medical decision making or time. In addition, the 2020 rule’s E/M add-on code GPC1X, which “reflects the time, intensity, and PE [practice expense] when practitioners furnish services that enable them to build longitudinal relationships with all patients (that is, not only those patients who have a chronic condition or single-high risk disease) and to address the majority of patients’ health care needs with consistency and continuity over longer periods of time” is expected to be billed with every E/M visit and is estimated to be $181M across all specialties. CMS is soliciting more specific information to inform refined language related to clarifying use of the GPC1X code.

Further, CPT code 99XXX represents a prolonged service code to be applied when time is used to determine the level of a code and exceeds the time of codes 99205 and 99215. While CMS accepted the RVU values of the 99XXX code, it changed the time elements for reporting. (See specific times for codes in CHEST Physician .) The proposed rules could have significant effects on CHEST members’ practices. We urge you to discuss these with your colleagues and submit comments before the October 5 deadline.

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