CMS Issues Proposed Rule for 2020 Medicare Physician Fee Schedule

On July 29, 2019, the Centers for Medicare & Medicaid Services (CMS) released the CY 2020  Revisions to Payment Policies under the Physician Fee Schedule and Other Changes to Part B Payment Policies [CMS-1715-P], which includes proposals related to Medicare physician payment and the Quality Payment Program (QPP). The proposed regulations will be published in the Federal Register on August 14, 2019. Comments are due September 27, 2019.

ASA leaders and staff will conduct a thorough review of this 1,704-page rule.  This posting includes initial highlights and more detailed information will be posted as we analyze all the elements in this rule. 

Medicare Physician Fee Schedule

 Proposed Increases to Conversion Factors:

• While there is no increase coming via the Medicare Access and CHIP Reauthorization Act (MACRA), a positive budget neutrality adjustment has resulted in a proposed increase of the Medicare Anesthesia conversion factor from $22.2730 to $22.2774.  The Resource Based Relative Value System (RBRVS) conversion factor is proposed to increase from $36.0391 to $36.0896.

New/Revised Codes:

• There are no new or revised CPT codes for anesthesia services
• There are new and revised codes for pain procedures, including new codes for sacroiliac (SI) joint and genicular nerve procedures.  There are also proposed work and PE RVU changes for certain somatic nerve injections. 
  • ASA is pleased with the CMS decision to accept the new codes.  ASA led efforts to obtain new codes to describe genicular nerve procedures and worked with other specialties to create new codes for SI joint RFA and on issues related to other somatic nerve injections.
  • ASA is disappointed by CMS’ proposed RVU changes for the somatic nerve injections and will contest these changes in our comments to the agency.  

Impact by Specialty:

• The payment rates are impacted by a range of proposed policy changes related to physician work RVUs, practice expense RVUs and malpractice RVUs. CMS summarizes these changes in Table 110 in the proposed rule.
• Proposed payment rate changes ranged from -4 percent for ophthalmology to positive 3 percent for clinical psychologists and clinical social workers. The anesthesiology impact was 0 percent and the impact on Interventional Pain Management is estimated as a positive 1%.
• Actual impact for a practice will vary based on service mix.

Merit-based Incentive Payment System (MIPS):

• CMS is proposing the following updates to the MIPS program for 2020 performance period (2022 payment period):
  • Out of 100 MIPS points available, 40% will be allocated to Quality, 20% to Cost, 25% to Promoting Interoperability (formerly Advancing Care Information) and 15% to Improvement Activities.
  • The proposed performance threshold for 2020 is 45 MIPS Total Points. Eligible Clinicians (ECs) or practices who fail to participate, when required, or to meet the 45-point threshold may incur up to a negative 9% payment adjustment in 2022.
  • The MIPS Quality reporting threshold is proposed to increase from 60% of eligible cases per measure to 70% of eligible cases.
  • Addition of Multimodal Pain Management measure to the Anesthesiology Measure Set.

The proposed regulations are available here
The fact sheet is available here
The QPP factsheet is available here