Medicare Compliance & Reimbursement

Hint: MVP is a go in 2021.

If you’re searching for what’s hot in the calendar year (CY) 2021 Medicare Physician Fee Schedule (MPFS) — beyond E/M service finalizations and the telehealth expansion — take a look at five must-know policies laid out in the final rule.

1. Medical documentation requirements: For CY 2020, the Centers for Medicare & Medicaid Services (CMS) finalized numerous changes to the medical record documentation requirements for physicians and other nonphysician practitioners (NPPs). Now in the CY 2021 final rule, CMS clarifies that “physicians and NPPs, including therapists, can review and verify documentation entered into the medical record by members of the medical team for their own services that are paid under the MPFS,” notes a fact sheet on the rule.

2. NCDs: Several outdated or obsolete National Coverage Determinations (NCDs) will be removed, effective Jan. 1, 2021. Medicare Administrative Contractors (MACs) will no longer have to follow “outdated coverage policies” on the six removed NCDs, and can instead determine beneficiary coverage based on geographic data and concerns, the agency indicates.

3. Teaching physicians: In the final rule, teaching physicians can now interact with their residents using interactive, real-time audio/video, allowing residents to meet certain requirements for key portions of service and procedures virtually.

4. E-Prescribing: “CMS finalized a requirement for all electronic prescribing for Schedule II, III, IV and V controlled substances to use a single national standard (i.e., the National Council for Prescription Drug Programs SCRIPT Standard) with an effective date of Jan. 1, 2021, and a compliance date of Jan. 1, 2022,” notes Miranda Franco, senior policy advisor with Holland & Knight LLP in Washington D.C., in online analysis.

5. Quality Payment Program (QPP): CMS solidified a few different QPP policies in the final rule.

• The agency plans to grant hardship exemptions on a case-by-case basis due to COVID-19 next year.
• The Merit-based Incentive Payment System (MIPS) Value Pathways (MVP) program was finalized, but CMS won’t roll out the transition until 2022.
• In the CY 2021 proposed rule, the agency proposed to change the performance threshold to 50 points to accommodate providers struggling with COVID- 19-related issues; however, CMS opted to keep it at 60 points next year.

Resource: See the PFS at https://public-inspection.federalregister.gov/2020-26815.pdf .