The Centers for Medicare and Medicaid Services (CMS) on Dec. 1 released the 2021 Medicare Physician Fee Schedule final rule, addressing Medicare payment and quality provisions for physicians in 2021. Physicians will see a conversion factor decrease on Jan. 1, 2021, going from $36.09 to $32.41. CMS estimates that the physician rule will increase payments to cardiologists by 1% from 2020 to 2021 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 and subspecialty.

The ACC has joined with the American Medical Association (AMA) and scores of other medical societies to argue that CMS should not make budget neutral payment adjustments to the conversion factor that balance increased payment for evaluation and management (E/M) services during the COVID-19 public health emergency (PHE). CMS did not make that change in the final rule. ACC continues to seek solutions to this unnecessary disruption, including legislation.

Highlights from the final rule include:

Physician Fee Schedule

• After proposing and revising changes to E/M documentation and payment in 2019 and 2020, the final 2021 rule includes final policies and rates for these services. Among the changes:

• Walking back a 2019 plan to pay a blended rate for level 2-4 visits, CMS will implement 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 on the revised definitions in order to address concerns about documentation burden in a manner that was less disruptive and correctly discerned differences in levels of E/M services.
• CMS finalized the adoption of revised and increased work RVUs for E/M services based on recommendations from the AMA Relative Value Scale Update Committee (RUC),
• Revaluing other services analogous to office E/M services, such as transitional care management, maternity care and end stage renal disease.

• The final rule includes updates to work and/or practice expense (PE) values for codes describing E/M, intracardiac echocardiography, transthoracic echocardiography, VAD interrogation, venography, and extracorporeal counterpulsation. More detail is available in the agency's supporting data tables when they are available. Additionally, the rule includes work and or PE values for new/revised codes describing extended external ECG monitoring, atrial septostomy, and percutaneous ventricular assist device services.
• The rule finalizes several professional scope of practice and related issues, including allowing supervision of diagnostic tests by certain non-physician providers (NPPs); pharmacists providing services incidents to physician's services; therapy assistants furnishing maintenance therapy; modifications to medical record documentation; and updates to payment for services of teaching physicians.
• The rule continues final revisions reflecting the current payment methodology finalized in the 2020 PFS and the addition of two new HCPCS codes, G2064 and G2065, to the general care management HCPCS code, G0511, for Principle Care Management Services furnished in Rural Health Clinics (RHC) and Federally Qualified Health Clinics (FQHC), beginning January 1, 2021. Additionally, the rule finalized the creation of new E/M CPT and HCPCS codes based on the methodology used to assign beneficiaries to accountable care organizations (ACOs) to reflect services for cognitive impairment and chronic management.
• After creating a process to remove outdated national coverage determinations (NCDs) in 2013, CMS finalized the use of those criteria within physician fee schedule rulemaking to remove nine NCDs. Coverage of FDG PET for Inflammation and Infection will no longer be nationally non-covered, but subject to local coverage by Medicare Administrative Contractors (MACs).

Medicare Telehealth and Other Services Involving Communications Technology

• The rule finalizes policy changes to maintain certain elements of the various telehealth flexibilities authorized on a temporary basis during the COVID-19 PHE, with some proposals made permanently and others lasting until the end of the calendar year in which the PHE ends. Among the services CMS is adding permanently to the Medicare telehealth list are:

• G2211 - Visit Complexity Associated with Certain Office/Outpatient E/Ms
• G2212 - Prolonged Services
• 99334, 99335 - Domiciliary, Rest Home, or Custodial Care Services
• 99347, 99248 - Home Visits

• CMS also finalized a temporary category of criteria for adding services to the list of Medicare telehealth services. The below are intended to be used during the COVID-19 PHE and will remain on the list through the calendar year in which the PHE ends.

• 99336, 99337 - Domiciliary, Rest Home, or Custodial Care Services
• 99349, 99350 - Home Visits, Established Patient
• 99281, 99282, 99283 - Emergency Department Visits
• 99315, 99316 - Nursing Facilities Discharge Day Management
• 96130, 96131, 96132, 96133 - Psychological and Neuropsychological Testing

• CMS will not make separate payment beyond the PHE for the audio-only telephone E/M services established in the March 31 COVID-19 interim-final rule. However, the agency proposes to create a new virtual check-in code for longer conversations of 11-20 minutes. G2252 is not meant to serve as a substitute for an in-person visit, but to assess whether an in-person visit is warranted. As an interim final proposal, this change is open to additional comment for 2022 rulemaking.

• CMS will also allow direct supervision to be provided using real-time, interactive audio and video technology (excluding telephone that does not also include video) through the end of the calendar year in which the PHE ends.

The final rule also addresses the 2021 Quality Payment Program (QPP) Performance Period. For detailed 2021 QPP highlights, click here. ACC staff are further 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. A fee schedule fact sheet is available here, press release here, and a QPP fact sheet is available here. Read about the 2021 Hospital Outpatient Final Rule, addressing Medicare payment and quality provisions for hospital outpatient services in 2021, here.

Keywords: ACC Advocacy, Relative Value Scales, Medicare, Centers for Medicare and Medicaid Services, U.S., Healthcare Common Procedure Coding System

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