Medicare Compliance & Reimbursement

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Medicare practices should prepare now for the 2021 rollout, especially if relative value unit (RVU) changes to E/M office/outpatient visits translate to fiscal shortfalls.

Details: The Calendar Year (CY) 2020 Medicare Physician Fee Schedule (MPFS) final rule — published in the Federal Register on Nov. 15 — outlines the Centers for Medicare & Medicaid Services’ (CMS) plans to update RVUs for CPT^® codes 99202-99215 starting in 2021. Though the changes won’t go into effect until next year, CMS offers a 2020 glimpse at what it expects the American Medical Association (AMA) Specialty Society Relative Value Scale Update Committee’s (RUC) recommended RVU will look like by specialty.

“Given that the revised codes and values do not take effect until CY 2021, CMS has not estimated the specific impact across the code set; however, it did publish illustrative implications in the proposed rule (Table 120),” explains Miranda Franco, senior policy advisor with Holland & Knight LLP in Washington D.C., in the Holland & Knight Healthcare Blog.

Estimated Impacts of Changes to RVUs for E/M Outpatient/Office Visit Codes

Source: Data from TABLE 120: Estimated Specialty Level Impacts of Finalized E/M Payment and Coding Policies from the CY 2020 MPFS
in the Federal Register on Nov. 15, 2019. See information at s3.amazonaws.com/public-inspection.federalregister.gov/2019-24086.pdf.

Explanation: The final rule suggests that CMS is reluctant to nail down any real numbers and offers only estimates. “We believe these estimates provide insight into the magnitude of potential changes for certain physician specialties, but note that Table 120 does not take into account other changes to payment rates finalized for CY 2020 and should be considered for illustrative purposes only,” the final rule advises.

“Furthermore, as the CY 2021 impact of the revalued office/outpatient E/M code set will be inclusive of policies finalized in that year’s rulemaking, we believe it would be premature to provide updated impacts for CY 2020,” CMS adds.

To get the estimated specialty calculations in Table 120, CMS used the finalized RVUs and the revalued HCPCS add-on code. However, more modifications may shake out in future rules, so don’t pin your hopes on these percentages just yet.