On August 3, the Centers for Medicare & Medicaid Services (CMS) issued a proposed rule
that includes updates to payment policies, payment rates and quality provisions for services furnished under the Medicare Physician Payment Schedule effective on or after January 1, 2021. AANEM policy staff is diligently reviewing the 1,300+ page rule but here are a few highlights from the proposal:
- A drastic 11% reduction in the Medicare conversion factor – the proposed conversion factor is $32.26, a significant decrease of $3.83 from the 2020 conversion factor of $36.09. This is due to the budget neutrality requirements and increased payments for new services and codes, as well as increases to some existing ones. AANEM staff is carefully analyzing and will calculate precisely what this would mean for EDX and NM codes. The AMA is already calling for temporary suspension of the budget neutrality requirement in light of the COVID-19 pandemic.
- Implementation of CPT’s recommendations for changes to the evaluation and management (E/M) codes, which AANEM representatives participated in.
- Permanently adding several telehealth codes that were temporarily added during the COVID-19 Public Health Emergency (PHE). CMS also proposes extending many of the other additional services included under the telehealth codes due to the PHE through the end of 2021.
- Slowing the gradual implementation of the Merit-based Incentive Payment System (MIPS) for 2021 and delaying implementation of the MIPS Value Pathways option until 2022. CMS does propose adding a new MIPS participation option for clinicians in alternative payment models (APMs) called the APM Performance Pathway (APP). A more gradual increase than previously proposed in the performance threshold for MIPS from 45 points in 2020 to 50 points in 2021. CMS also proposes lowering the weight of the Quality category from 45% to 40% and raising the weight of the Cost category from 15% to 20% for 2021.
- Expanding the scope of practice for some nonphysician providers. AANEM staff will very carefully review this section to determine what, if any, impact this could have on EDX testing or NM care.
Once AANEM staff is finished reviewing the rule, they will work with the AANEM Board of Directors to craft a comment letter on the proposal which will be shared with membership in the next couple of months. If you have questions or concerns about the proposed rule, you can email the policy department at firstname.lastname@example.org