Proposed Rule – 2021 Medicare Physician Fee Schedule

On August 3rd, the Centers for Medicare and Medicaid Services (CMS) published the 2021 Medicare Physician Fee Schedule, which includes CMS only allowing a comment period of 30 days for the draft (instead of the normal 60 day period).

Proposed 2021 Conversion Factor

The proposed 2021 Conversion Factor is $32.2605, a 10.61% decrease from 2020 ($36.0896).

The separately calculated Anesthesia Conversion Factor is proposed at $19.9631, a 10.08% decrease from 2020 ($22.2016).

The drastic decrease can be associated with CMS choosing to move forward with the new coding structure for the office/outpatient evaluation and management (E/M) codes.

Estimated Impact on Total Allowed Charges by Specialty
  • Anesthesiology: -8%
  • Emergency Medicine: -6%
  • General Surgery: -7%
  • Internal Medicine: +4%
  • Interventional Radiology: -9%
  • Multispecialty Clinic/Other Phys: -4%
  • Pathology: -9%
  • Radiology: -11%

Recap on Telehealth

It is anticipated that CMS will issue a separate regulation to adopt more of the temporary telehealth polices that it did not propose to adopt in the PFS permanently.

Virtual Check-In Codes

  • CMS is proposing to adopt some Virtual Check-In Codes, values permanently, and approved practitioner-types that can furnish these services.

Audio-only Telehealth Services

  • CMS will not propose to adopt specific audio-only telehealth codes beyond the expiration of the PHE.
Highlights of the Quality Payment Program

Overall, CMS is not proposing drastic changes to QPP to allow continued focus on responding to COVID-19.

  • CMS proposes a new Alternative Payment Model (APM) and Alternative Performance Pathway (APP) reporting option in 2021, creating an MVP for how EC’s can transition from MIPS to APM.
  • By law, CMS must weight the Quality and Cost categories at 30% of a clinician’s score by 2022.
  • The performance threshold plans to reduced to 50 points.
  • The quality category to be weighted at 40%, cost performance at 20%, Interoperability to be 25%, and Improvement Activates at 15%.
  • CMS is proposing to change 112 MIPS quality measures and remove 14 measures.

Sources: CMS Resource Library