CMS Releases 2021 Medicare Physician Fee Schedule/Quality Payment Program Final Rule

On December 1, 2020, the Centers for Medicare & Medicaid Services (CMS) released its Final Rule for the CY 2021 Medicare Physician Fee Schedule (MPFS) and the 2021 Quality Payment Program.

Included within the rule is the announcement that the 2021 Medicare Conversion Factors (CF) will be:

Anesthesia $20.0547  (a decrease from the 2020 CF of $22.20)

RBRVS $32.41 (a decrease from the 2020 CF of $36.77)

These CF’s will be applied to services provided on/after January 1, 2021.

These dramatic decreases are due to a budget neutrality requirement that has been triggered by an  increased valuation of office/outpatient Evaluation and Management (E/M) services. According to CMS estimates in the rule, the impact on specific specialties ranges from a positive 16% to a negative 10%.  Specialties whose members provide a higher volume of office/outpatient E/M will see increases while other specialties who are more procedural and/or facility based will see decreased payments. 

The estimated impact on anesthesiology is -8% and the estimated impact on critical care is -7%.  Physicians from these areas of medicine are at the forefront of the battle against COVID. 

These lower payments which are almost solely due to regulatory/statutory requirements that yearly changes to Medicare spending be contained within a range established decades ago are significant threats to our entire health system.  

America’s healthcare system – including anesthesiologists and other physicians and healthcare professionals  - is  under an unprecedented level of stress and strain.  The current and anticipated surge in COVID-19 infections will require more and more from our front-line physicians while paying them less and less. The impact of these devasting cuts will not be limited to Medicare beneficiaries but will affect all patients seeking care for any reason.  

ASA is currently working on our own and in collaboration with other effected specialties to convince Congress to mitigate the payment cuts  and take care of the professionals that are taking care of all Americans.  

The anesthesia code set remains stable and there are no changes to the base unit values for CY2021.  

Quality Payment Program

 The rule provides details on how the Merit-based Incentive Payment System (MIPS), Alternative Payment Models and other features of the QPP will operate during the 2021 performance year as well as some guidance on the development of MIPS Value Pathways for 2022.

In 2021, QPP participants will see some modifications to the program, including:

• The MIPS performance threshold will be set at 60 points. Individuals and groups receiving less than 60 points will incur a payment penalty (under 15 points incurs a -9% adjustment) in 2023 and those earning more than 60 points will receive a payment increase in 2023. 
• The quality performance category will be weighted at 40% and the cost performance category will be weighted by 20%. Promoting interoperability and Improvement Activities performance categories will maintain their respective 25% and 15% weights.

Other features of the program will remain the same as in 2021. These include:

Eligibility requirements, special statuses, and the ability to opt-in to report MIPS;

• The Anesthesiology MIPS measure set; and
• Requirements that 50% of the NPIs in a practice must participate in the same Improvement Activity during any 90-day period in the performance period.
• CMS has also released some guidance on MIPS Value Pathways (MVPs) for the 2022 performance period. ASA is encouraged by CMS direction that MVPs take into consideration multiple specialties that contribute to an episode of care. 

ASA expects to update its Quality Payment Program website in the next few weeks with regulatory information and the Anesthesia Quality Institute expects to publish its 2021 QCDR measures book by mid-December as well. CMS expects to publish the 2021 MIPS measure specifications and other regulatory guidance within the next few weeks on the QPP website.  

For more information on the Quality Payment Program, please contact the ASA Department of Quality and Regulatory Affairs (QRA) at [email protected]. 

The full rule – with all payment and QPP provisions is available here.