A recent Revenue Cycle Intelligence article shared the Centers for Medicare and Medicaid (CMS) final 2021 Physician Fee Schedule rule. It does not make sense that during a Public Health Emergency (PHE) a significant RVU change should take place with financial implications for physician practices already having financial difficulty.
The 2021 conversion factor is approximately 10% lower than 2020. There has also been a shift in relative work values (RVUs) in 2021 compared to 2020. The shift in RVUs will benefit primary care providers and hurt specialty care providers.
The final rule unveiled by CMS yesterday evening will dictate how much Medicare physicians get paid for delivering care starting January 1, 2021. In the rule, CMS finalized a conversion factor of $31.41, which is a decrease of $3.68 compared to the previous year’s conversion factor.
The decrease stems from the statutory requirement that the Physician Fee Schedule remains budget neutral in the event revisions to the RVUs that determine physician reimbursement result in changes of more than $20 million.
In 2021, the Physician Fee Schedule is slated to experience expenditures changes of this magnitude because of revisions to the RVUs for evaluation and management (E/M) services, CMS explained.
The agency finalized increases in RVUs for common office/outpatient E/M services, including maternity care bundles, emergency department visits, end-stage renal disease capitated payment bundles, and physical and occupational therapy evaluation services.
Industry groups argued that the increases would trigger the budget neutrality requirement, causing CMS to reduce the RVUs for other services, including specialists who have been on the frontline of the COVID-19 pandemic, such as critical care and emergency medicine providers.
CMS said in the final rule that the increases are meant to support primary care clinicians who are facing a growing number of Medicare beneficiaries, including many with one or more chronic conditions. The agency also believes the final rule will also aid other clinicians by reducing E/M documentation burden through a more streamlined reporting process for E/M levels.
The agency also finalized a new category of telehealth benefits under the Physician Fee Schedule. The new Category 3 list will include telehealth services covered by Medicare during the public health emergency and through the calendar year in which the emergency declaration expires.
The Category 3 list includes services like home visits for established patients, emergency department visits levels one through five, hospital discharge day management, critical care services, and nursing facility discharge day management.
The agency also clarified in the final rule that licensed clinical social workers, clinical psychologists, physical therapists (PTs), occupational therapists (OTs), and speech-language pathologists (SLPs) can deliver brief online assessment and management services, as well as virtual check-ins and remote evaluation services. The final rule includes two new codes to support billing for telehealth services delivered by these providers.
Additionally, CMS created a new code for audio-only telephone services based on support from industry stakeholders who have leveraged telephonic care during the pandemic. The code accounts for 11 to 20 minutes of medical discussion to determine the necessity of an in-person visit.
To view the complete final rule, click here. Please note that the final rule has not yet been published for public display in the Federal Register. The public will be able to comment on the final rule once it is published for public display. Readers can also view a CMS fact sheet on the rule here.
This is one of the most significant changes to the physician RVUs in over 30 years. We believe that Congress should consider suspending this physician rule until further review by the new administration and after the PHE has ended.