More on the proposed 2020 Medicare fee schedule

We recently reported on the release of the proposed 2020 Medicare Physician Fee Schedule, and the changes it will mean for allergists. The biggest proposed change for allergy services is an increase in the venom immunotherapy codes ranging from 3.4 to 7.6% in 2020. This increase is a result of changes approved last year and is the second year of a four-year phase-in.

The College recently participated in a Centers for Medicare and Medicaid Services (CMS) briefing on the proposal, hosted by the American Medical Association. The meeting was extremely beneficial and provided us with some additional information about the new Schedule.

Additional proposed changes in payment for other allergy services are summarized below:

Online Non-Face-to-Face Digital Evaluation Services for 2020

CMS is proposing to add and reimburse for six new codes to describe patient-initiated non-face-to-face evaluations that require a clinical decision. Three of the new codes are CPT codes that describe services by physicians or other qualified health care professionals; the other three are G codes that describe services provided by clinical staff.All codes describe services provided during a period of up to seven days and go from 5–10 minutes; 11–20 minutes; and 21 or more minutes. Although CMS has provided little detail on what types of digital communications this includes, these codes may allow allergists that use patient portals or encrypted email or texting to communicate with patients to get paid for this service.

E/M Changes Proposed for 2021

As previously reported to members, separate payment rates for all E/M levels would be maintained, rather than consolidated. According to the CMS impact tables, allergy/immunology could see overall increases in Medicare revenue of 6–7% in 2021.

In addition:

  • Physicians will be able to select the level of E/M visit based on either medical decision making OR on time (including both physician’s face-to-face and non-face-to-face time).
  • Use of history and/or physical exam to select among code levels, including outdated requirement of documentation of number of body systems/areas reviewed, will be eliminated. Documentation of patient history and a medical examination will only be required when clinically appropriate.
  • A new prolonged visit code, 99XXX, could be added to time-based level 5 outpatient visit codes (99205, 99215).  The new code would describe increments of 15 minutes of additional visit time and have .61 work RVUs.
  • CPT Code 99201 (new patient level one office visit) will be deleted.
  • Two previously proposed complexity add-on codes would be consolidated into one add-on code, GPC1X. This code could be reported with all outpatient E/M visits that are related to a patient’s single, serious or complex chronic condition.

2020 Merit-based Incentive Payment System (MIPS) Proposals

  • There would be no change to the low-volume threshold criteria. To be excluded from MIPS, clinicians or groups would need to meet one of the following three criteria: 1) <= $90,000 in allowed charges, 2) <= 200 Medicare beneficiaries, or 3) <= 200 covered professional services.
  • Eligible clinicians and group practices would continue to be evaluated in the same four categories, but the weighting would change: quality (40 points), cost (20 points), promoting interoperability (25 points) and improvement activities (15 points).
  • Penalties based on 2020 performance would increase to up to 9% in 2022. To avoid a penalty, a score of 45 points would be required in 2020, up from 30 points in 2019.
  • CMS would maintain a six-point small practice bonus, which would be applied to the quality category.

The Advocacy Council plans to submit comments on the proposed rule. We’ll continue to update you about any additional proposals – and how they will impact allergists. Keep watching Advocacy Insider for details.

Advocacy Issue: 
Billing, Coding & Payments