On December 1, 2020, the Centers for Medicare & Medicaid Services (CMS) released the 2021 Medicare Physician Fee Schedule (PFS) Final Rule and policy changes to the Quality Payment Program (QPP) for 2021.
The Final Rule adopted the proposed changes to coding policies for office and outpatient EM codes. (Note: the office and outpatient codes do not include the Emergency Medicine CPT codes 99281-99285/99291.) The office and outpatient coding changes will result in an increase in payments for the office and outpatient EM codes.
Because of budget neutrality requirements, CMS cut the conversion factor to offset these payment increases. The cut to the conversion factor will decrease Emergency Medicine reimbursement an estimated 6.6%. The 2021 conversion factor is $32.40, a 10.2% decrease from 2020 conversion factor of $36.08. The decrease to Emergency Medicine was slightly offset by an increase in wRVU for Emergency Medicine CPT codes.
This cut will impact Medicare Part B and Medicare Advantage plan reimbursement, as well as any managed care contracts based on prevailing Medicare. As contracts are eligible for renewal in 2021, Gottlieb will make every effort to renegotiate the commercial rates from prevailing Medicare to a fixed year.
The Final Rule also addressed changes to MIPS (the Quality Payment Program) and Telehealth which will be summarized for by Gottlieb in a later publication.
CMS estimates an overall impact to the physician fee schedule of (Table 106 in the Rule, Page 1660):
- Emergency Medicine: -6%
- Critical Care: -7%
- Hospital Medicine: no estimate provided by CMS
- Primary Care/Urgent Care: no estimate provided by CMS
Immediate action by Congress is needed to avoid implementation of these cuts. ACEP and other specialty societies have responded. Per ACEP, “ACEP, along with a coalition of organizations representing more than 1 million physicians and allied health professionals, support including the “Holding Providers Harmless From Medicare Cuts During COVID-19 Act of 2020” in any year-end legislative package.” Likewise, the Hospitalist Society has supported this bill.
You are encouraged to contact your House and Senate representatives as soon as possible.
It is important to note that the sequestration policy could also become effective again in 2021 resulting in an additional 2% cut to Medicare payments.
We will provide you with more details on the Final Rule over the next few weeks or Contact Us Today.