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CMS Issues CY 2020 Physician Fee Schedule Final Rule

The Centers for Medicare & Medicaid Services (CMS) published a Medicare Physician Fee Schedule (PFS) final rule for calendar year (CY) 2020.

The PFS final rule includes these provisions of interest to essential hospitals:

  • Payment updateCMS will increase the annual physician payment rate by 0.14 percent;
  • Evaluation and management (E/M) servicesCMS finalized its proposal to pay separately for nine different levels of E/M visits in CY 2021 — levels one through four for new patients (current procedural terminology [CPT] codes 99202–99205) and levels one through five for established patients (CPT codes 99211–99215). This is a reversal from the blended payment rates CMS  proposed in the CY 2019 final rule, which would have consolidated the payment rate for levels two through four for new and established patients beginning in CY 2021;
  • Telehealth servicesAs part of several provisions related to treatment of opioid use disorder (OUD), CMS finalized a proposal to add three new codes describing a bundled episode for OUD treatment to the list of telehealth services for which it will reimburse Medicare providers; and
  • Medicare Shared Savings Program (MSSP): CMS will continue to explore future updates and changes to the MSSP quality scoring methodology to align with the Merit-based Incentive Payment System (MIPS) quality performance category.

Quality Payment Program Updates

Under the QPP, eligible clinicians participate in one of two tracks: the default MIPS or Advanced Alternative Payment Models (APMs).

For CY 2020 — year four of the program, which equates to the 2022 payment year — CMS will maintain many of the requirements from the 2019 performance year while finalizing new policies allowing clinicians to choose how to participate in either the MIPS or Advanced APM tracks.

For MIPS, CMS finalizes several changes, including:

  • increasing the performance threshold (from 30 to 45 points) for earning positive payment adjustments;
  • maintaining the option to use facility-based scoring (for quality and cost measures) that does not require data submission for facility-based clinicians;
  • retaining bonus points in the scoring methodology for the care of complex patients;
  • maintaining the weights of all four performance categories for the 2020 performance period (quality at 45 percent; cost at 15; promoting interoperability at 25; and improvement activities at 15);
  • adding seven new specialty sets in the quality performance category; and
  • adding 10 new episode-based measures and revising the total per-capita cost and the Medicare Spending Per Beneficiary (MSPB) measures in the cost category.

For Advanced APMs, CMS will maintain the existing 8 percent revenue-based nominal risk standard through performance year 2024. After further review of its current data systems, and citing operational limitations, CMS is not finalizing its proposal to apply partial qualifying APM participant (QP) status only to the tax identification number/national provider identifier combination(s) through which an individual eligible clinician attains partial QP status.

MIPS Value Pathways

Beginning with the CY 2021 performance year, CMS will introduce over time MIPS Value Pathways (MVPs). This new participation framework aims to align and connect measures and activities across the four performance categories of MIPS for different specialties or conditions.

CMS will host a webinar on the Outpatient Prospective Payment System and PFS final rules on Nov. 6 from 2:15–3:45 pm ET.

America’s Essential Hospitals is analyzing the final rule and will send members a detailed Action Update in the coming days.

Contact Senior Director of Policy Erin O’Malley at or 202.585.0127 with questions.


About the Author

Maryellen Guinan is a principal policy analyst at America's Essential Hospitals.

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