Medicare has rolled out the 2020 Physicians Fee Schedule (PFS) and it is quite a disappointment for those who were looking to see a jump in the conversion factor this year. The 2020 PFS conversion factor (36.0896) represents an increase of just a nickel over 2019 (36.0391). This modest update, unfortunately, continues a concerning trend of relatively flat Medicare payment updates that are not keeping up with the cost of inflation or furnishing care to Medicare beneficiaries.
However, there are still huge opportunities to earn more through adopting technology, restructuring some existing resources, and changing the documentation style of your current EMR for coding changes that will take effect in the year 2020-21. Listen to the full podcast here.
Here are the key takeaways from the new rules that take effect in 2020 MGMA has published a recent article about it which can be accessed here.
- E/M Services documentation and payments: New changes are arriving for clinicians beginning January 1st, 2021. Instead of using the history and exam elements traditionally used to select the appropriate E/M level of the visit, clinicians will need to select the appropriate E/M level based on the medical decisions made in the exam or time personally spent by the reporting practitioner on the day of the visit (includes face-to-face and telemedicine). CMS will maintain separate payments for all E/M levels for new and established patients. Furthermore, in 2021, CMS will eliminate level 1 visits for new patients (code 99201). As well as, implement add-on codes for visit complexity (for specific types of visits) and external visits (99XXX).
- Opportunities for 20% more income: New E/M coding guidelines are intended to be more intuitive, reduce unnecessary documentation, and increase billing flexibility. Fully integrating documentation revisions into practice management and clinical workflow will take time and may involve coordination with third-party vendors. Afterward, your EHR company will correctly set up templates that will reduce documentation, allowing you to see more patients. As a result, the requirement around E/M documentation should become more flexible and streamlined for the purpose of medical billing. Updates to the MIPS and APM Policies: The performance threshold to avoid a payment penalty is 45 points and the exceptional performance threshold is 85 points. By statute, the 2022 payment adjustment (based on 2020 performance) is +/- 9% while the 10% for exceptional performance will still be available. So here you have an opportunity to make an additional 19% more on Medicare beneficiary if your performance is 85 points.
- Verification of Medicare Records documentation: Starting January 1st, 2020 CMS eased requirements for Medical Record documentation by allowing physicians to review and verify (sign & date) notes made by their PAs and nurses. Before, this kind of flexibility was only available to teaching physicians. This will free up to 20% of a physician’s time which earlier was being spent in redocumentation or creating charts themselves. There is also a minor change in PA supervision which will allow PAs to practice in accordance with state law supervisor rule, instead of the Medicare general supervision requirements. This change in policy aligns physician supervision requirements for PA services with the physician’s collaboration requirements for nurse practitioners and clinical nurse specialists. In turn, this reduces practical differences in PA and NP/CNS utilization and does not impact incident to billing.
- Increase reimbursement opportunity in TCM, CCM, and PCM services: Under existing policy, transitional care management (TCM) services cannot be billed concurrently with 57 codes during the 30-day period covered by TCM. Starting 2020 CMS will allow TCM billing with 16 codes previously prohibited from concurrent billing. These include prolonged services without a direct patient contract and chronic care management. Additionally, CMS increased the payment by adopting the AMA RUC recommended work RVU of 2.36 for CPT code 99495 and 3.10 for CPT 99296 from 2.11 and 3.05 in the year 2019 respectively. For groups already billing for CCM services, the addition of the new add-on code 99490 for noncomplex CCM 20-minutes, should offer additional reimbursement opportunities. CMS also finalized new coverage with a new code describing “Principal Care Management” (PCM) which is similar to CCM but instead is intended for patients with only one complex chronic condition. Starting Jan. 1, 2020 G2064 can be billed for PCM.
- Opportunities if you adopt technology and promote interoperability: Telehealth or the use of communication-based technology services will yield more reimbursements. The inclusion of three new codes G2086, G2087, and G2088 will help in expanding access to telehealth for individuals with substance use disorders. These newly added telehealth services will be furnished by Medicare beneficiaries. In the 2020 PFS, CMS finalized a policy to permit a single advanced beneficiary consent for multiple communication-based technology and consultation services that will cover a one-year period. Use technology to your advantage will greatly advance your practice. Begin by utilizing an online patient portal for payments, offer telemedicine services, verify benefits digitally, allow patients to schedule through your website or patient portal. Secondly, adopt and promote interoperability. Thanks to a modification in the reweighing policy for hospital-based physicians, clinicians will be eligible for reweighting in this category when more than 75% of clinicians in the group meeting the definition of hospital-based.
Kunal Jain is the co-founder of PracticeForces Medical Billing and IT consulting company in Clearwater, Florida.