July 30, 2019
The proposed 2020 Medicare Physician Fee Schedule was just released and, if adopted, will mean some changes to allergist reimbursement.
The biggest change is in the venom immunotherapy codes, all of which increase from 3.4 to 7.6% in 2020, as a result of changes approved last year. Changes are being phased in over four years, with 2020 being the second year of the phase-in. There are small changes in payment for other allergy services; however, CMS estimates a less than 1% change in total Medicare revenues for allergy/immunology if the rates and policies in the proposed rule are adopted.
Conversion factor: The proposed conversion factor is $36.0896, an increase of .14 percent from this year’s conversion factor of $36.0391. The conversion factor is the dollar amount that is multiplied by the RVUs to determine reimbursement.
Principal Care Management Code: CMS is also proposing a new G code for care management of patients with a single chronic condition. Current chronic care management (CCM) codes require a patient to have two or more chronic conditions. The new G code (GPPP1) could be used for care management services for a single high-risk disease when the physician or qualified health professional spends at least 30 minutes per month. The following criteria would apply:
- The patient has a chronic condition lasting at least 3 months.
- The condition is of sufficient severity to place the patient at risk of hospitalization or has been the cause of a recent hospitalization.
- The condition requires development of a disease-specific care plan with frequent adjustments in medication or the condition is unusually complex due to comorbidities.
The proposed payment for this new service is approximately $82 per month. Allergists may be able to bill this service for care management provided to complex asthma patients.
Another new G Code, GPPP2, could be used for similar care management services provided by clinical staff. Reimbursement for this service would be approximately $40.
Evaluation and management (E/M) services changes for 2021: One important change in the proposed rule relates to payment for E/M services. The impact of the change will not be implemented until 2021. CMS announced that it has reversed its decision to consolidate E/M levels 2-4 into a single payment amount and has decided, instead, to accept the American Medical Association CPT and RVS Update Committee (RUC) recommendations which preserve separate payment for each visit level. In addition, it proposes to accept the RUC recommendations on valuation. These changes, which would take effect in 2021, would result in higher payment for E/M services. CMS impact tables estimate an overall increase in Medicare payment of 6 to 7% for allergy and immunology if the E/M proposals are finalized for 2021.
Reducing regulatory burden: There are a number of new policies that are intended to reduce documentation burden, including allowing practitioners to verify, rather than redocumenting, entries of other care team members.
Physician Assistants (PAs): CMS is proposing more flexibility in regulation of physician supervision of PAs and would allow them to practice to the extent allowed by state law. Physician supervision would be evidenced by documentation in the medical record.
The Advocacy Council will be reviewing the proposed rule in detail. Watch for additional information detailing some of the proposals.
The Advocacy Council – we’ve got your back.