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Medicare proposed rule for CY 2020 PFS


Medicare Physician Fee Schedule (PFS)

On July 29th, CMS issued a proposed rule to make changes to the physician fee schedule (PFS) rules and other related policy changes. Major aspects of the proposed rule include updates to the PFS rates, changes to the leveling codes, new fee schedule reimbursement for aspects of patient care managements, updates to Merit-based Incentive Payment System (MIPS), and new provisions for reimbursement for opioid substance abuse related treatment.

Fee schedule rate update 
Under the proposed rule, CMS would increase physician fee schedule rates by 0.14% in calendar year 2020 as shown in the following table:

CY 2019 Conversion Factor 36.0391
   CY 2020 RVU Budget Neutrality Adjustment 0.14%
CY 2020 Conversion Factor 36.0896

E&M leveling codes
Rule makers propose reverting back to payment rates for all five levels of E&M codes in lieu of the blended methodology for certain levels adopted in the prior year final rule.

Care management
In an effort to improve payment for care management and coordination, CMS proposes to expand the codes associated with these services. CMS is attempting to eliminate gaps in payment for care management through this rule. The proposal recognizes the importance of care management for treatment of patients with chronic conditions.

CMS proposes to take steps to align the reporting requirements across the four MIPS performance categories to reduce the burden on physicians. In addition, the proposed rule would adjust the weighting of cost and performance criteria associated with the program.

Coverage for opioid use disorder treatment
CMS is proposing codification of a new Medicare benefit category that would outline payment for treatment of opioid use disorder furnished by Opioid Treatment Programs (OTP). The proposal specifies how Medicare would pay for treatment in an OTP based on methods that have a track record of success.

CMS is currently soliciting public comments regarding the proposed rule. The comment ends September 27, 2019. 

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