On July 29, 2019, the Centers for Medicare and Medicaid Services (CMS) released the CY 2020 Proposed Rule for the Medicare Physician Fee Schedule (MPFS), which also includes proposals related to 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. While AAO-HNS physician leaders and staff are still reviewing the over 1,700 page rule, a high-level analysis identified key proposals impacting the specialty.
For 2020, CMS proposes a conversion factor of $36.09, a slight increase from the $36.04 factor in 2019. The rule outlines the agency’s plans to implement many of the changes to E&M codes first introduced in last year’s regulations. CMS is proposing to adopt the CPT-approved updates to E/M visits approved for 2021, which retain 5 levels of coding for established patients, reduce the number of levels to 4 for new patients, and revise the code definitions. CMS is also proposing to implement the RUC-recommended E/M values for CY 2021, which are substantially higher than the current values. However, the rule does not extend these values to the post-operative office visits included in global surgery bundled payments. In Table 111 of the rule, CMS estimates that otolaryngology will receive an overall 5% increase based on the proposed revisions to E/M payment and coding policies.
CMS is proposing the following updates to the Merit-based Incentive Payment System (MIPS) program for the 2020 performance period (2022 payment period). Out of 100 MIPS points available, 40% will be allocated to Quality, 25% to Promoting Interoperability (formerly Advancing Care Information), 20% to Cost, 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 meet the performance threshold, may be subject to a negative 9% payment adjustment in 2022.
The Academy is continuing its analysis of the rule and plans to submit comments by the September 27 deadline.