On July 29, the Centers for Medicare and Medicaid Services (CMS) released the proposed 2020 Medicare Physician Fee Schedule, addressing Medicare payment  and quality  provisions for physicians in 2020. Under the proposal, physicians will see a virtually flat conversion factor on Jan. 1, 2020, going from $36.04 to $36.09. CMS estimates that the physician rule will increase payments to cardiologists by three percent from 2019 to 2020 through updates to work, practice expense, and malpractice RVUs. This estimate is based on the entire cardiology profession and can vary widely depending on the mix of services provided in a practice.

The Physician Fee Schedule was released in tandem with the proposed 2020 Hospital Outpatient Prospective Payment System rule. The outpatient rule indicates a 2.7 percent payment update for hospitals and other proposals. Highlights from both proposed rules include:  

Physician Fee Schedule

• After proposed changes to evaluation and management (E/M) payment were both altered and/or delayed until 2021 in the calendar year 2019 final rule last November, CMS proposes additional revisions to E/M documentation and payment policies. 

• Walking back a prior plan to pay a blended rate for level 2-4 visits, CMS proposes to adopt revised E/M code definitions developed by the AMA CPT Editorial Panel starting Jan. 1, 2021. Members from across the House of Medicine worked together to find a way to respond to concerns about documentation burden in a manner that was less disruptive and correctly discerned differences in levels of E/M services.

• The proposal to adopt revised coding definitions is paired with a decision to pay for each level of service rather than utilize a blended rate.

• Incorporating recommendations from the AMA Relative Value Scale Update Committee, CMS proposes to adopt revised work and practice expense inputs for E/M services.  

• CMS proposes no changes regarding implementation of the mandate requiring that clinicians consult appropriate use criteria through a qualified clinical decision support mechanism (CDSM) starting Jan. 1, 2020, when ordering advanced imaging services (i.e., SPECT/PET MPI, CT and MR). Requirements were recently summarized in this MLN Matters article.

• A request for information regarding changes that could be made to the Stark Law advisory opinion process.

• Updates to work and/or practice expense values for codes describing transcatheter aortic valve replacement (TAVR), remote loop recorder interrogation and remote cardiac monitor interrogation, noncoronary intravascular ultrasound (IVUS), and abdominal aortography. More detail will be available after CMS posts supporting data tables.

• Proposed work and or practice expense values for new/revised codes describing self-measured blood pressure monitoring, ambulatory blood pressure monitoring, remote physiologic monitoring, pericardiocentesis and pericardial drainage, myocardial strain imaging, and myocardial PET.

2020 Quality Payment Program Performance Period

• Increase in the performance threshold from 30 points in 2019 to 45 points in 2020, and 60 points in 2021.

• Additional increase for exceptional performance to 80 points in 2020 and to 85 points in 2021.

• Revision of the performance category weights for Quality to 40 percent in 2020, 35 percent in 2021, and 30 percent in 2022 performance year.

• Increase in Cost performance category for Cost to 20 percent in 2020, 25 percent in 2021, and 30 percent in 2022 performance year.

• Revision of the specifications for the Total Per Capita Cost and Medicare Spending Per Beneficiary Clinician measures (adding 10 new episode-based measures).

• Maintaining Promoting Interoperability and Improvement Activities at 25 percent and 15 percent, respectively.

• Maintaining performance-based scoring on individual measures under Promoting Interoperability performance category.

• Increase in the data completeness threshold for the quality data that clinicians submit.

• Increase in the threshold for clinicians who complete or participate in the Improvement Activity for group reporting.

• Updates to requirements for Qualified Clinical Data Registry (QCDR) measures and the services that third-party intermediaries must provide (beginning with the 2021 performance period).

• Application of a new Merit-Based Incentive Payment System (MIPS) Value Pathways (MVPs) framework to future proposals beginning with the 2021 MIPS Performance Year. MVPs would utilize sets of 106 measures and activities that incorporate a foundation of promoting interoperability and administrative claims-based population health measures and layered with specialty/condition specific clinical quality measures to create both more uniformity and simplicity in measure reporting.

• Maintaining low-volume threshold, eligible clinician types, MIPS performance periods, CEHRT requirements, and small practice bonus points.

Hospital Outpatient Rule 

• A proposed requirement for hospitals to make public standard charge amounts for 300 “shoppable” services.

• Addition of codes describing angioplasty and stent PCI to the Ambulatory Surgery Center Covered Procedures list for calendar year 2020.

• Executing the second of a two-year phase in to cap payment for off-campus hospital clinic visits at a rate equivalent to the physician fee schedule rate.

• The removal of one measure from the Hospital Outpatient Quality Reporting Program for the 2022 Program Year. 

ACC staff are reviewing the proposed rules to identify additional topics of interest to members. More information will be forthcoming in the Advocate newsletter and on ACC.org in the coming weeks. Additional CMS fact sheets are available here and here and here. The College will submit written comments in the coming weeks.

Not long before the final rules are released in the fall, experts will discuss federal legislative and regulatory topics at ACC’s 2019 Legislative Conference Nov. 3-5 in Washington, DC. Don’t miss this opportunity to learn about hot button issues facing cardiologists and to ensure the voice of cardiology is heard on Capitol Hill. Access online registration here.

Keywords: Relative Value Scales, Blood Pressure Monitoring, Ambulatory, Transcatheter Aortic Valve Replacement, Blood Pressure, Decision Support Systems, Clinical, Outpatients, Pericardiocentesis, Aortography, Ambulatory Surgical Procedures, Medicare, Fee Schedules, Medicaid, Physicians, Angioplasty, Malpractice, Registries, Stents, Prospective Payment System, Ambulatory Care, Percutaneous Coronary Intervention, ACC Advocacy

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