The Centers for Medicare and Medicaid Services (CMS) has released the 2021 proposed rule on the physician fee schedule and Quality Payment Program.
Highlights of the drafted rule include the following:
Payment update: As required by statute, the update to the physician fee schedule conversion factor for CY 2021 is 0.00 percent before applying other adjustments. After accounting for this update and the budget neutrality adjustment, the proposed conversion factor for CY 2021 is $32.26, a decrease of $3.83 from the CY 2020 conversion factor of $36.09.
Streamlining Evaluation and Management (E/M) payment and reducing clinician burden: As finalized in the CY 2020 PFS final rule, CMS is implementing significant coding and payment changes intended to streamline and offer flexibility in documentation requirements for E/M office visits, beginning January 2021.
CMS is proposing to revalue the following code sets that include, rely upon or are analogous to office/outpatient E/M visits commensurate with the increases in values finalized for office/outpatient E/M visits for 2021:
- End-Stage Renal Disease (ESRD) Monthly Capitation Payment (MCP) Services
- Transitional Care Management (TCM) Services
- Maternity Services
- Cognitive Impairment Assessment and Care Planning
- Initial Preventive Physical Examination (IPPE) and Initial and Subsequent Annual Wellness (AWV) Visits
- Emergency Department Visits
- Therapy Evaluations
- Psychiatric Diagnostic Evaluations and Psychotherapy Services
Professional scope of practice: Starting January 1, 2021, CMS is proposing to make permanent after the COVID-19 public health emergency (PHE), the following policies that were finalized under the May 1, 2020 COVID-19 interim final rule with comment period (IFC) for the duration of the COVID-19 PHE.
- Allow nurse practitioners (NPs), clinical nurse specialists (CNSs), physician assistants (PAs) and certified nurse-midwives (CNMs) to supervise the performance of diagnostic tests in addition to physicians.
- Allow a physical therapist (PT) and occupational therapist (OT) to delegate the performance of maintenance therapy services, as clinically appropriate, to a therapy assistant – a physical therapist assistant (PTA) or an occupational therapy assistant (OTA). CMS is also proposing to revise subregulatory provisions to clarify that PTs and OTs no longer need to personally perform maintenance therapy services and to remove the prohibitions on PTAs and OTAs from furnishing such services.
CMS also clarifies in the proposed rule that:
- Pharmacists may provide services incident to the services, and under the appropriate level of supervision, of the billing physician or NPP, if payment for the services is not made under the Medicare Part D benefit.
- Physicians and NPPs, including therapists, can review and verify documentation entered into the medical record by members of the medical team for their own services that are paid under the PFS; and therapy students, and students of other disciplines, working under a physician or practitioner who furnishes and bills directly for their professional services, may document in the record so long as it is reviewed and verified (signed and dated) by the billing physician, practitioner, or therapist.
Finally, CMS is considering whether to extend flexibilities granted to teaching physicians and their residents during the COVID-19 PHE on a temporary basis and is inviting comments.
Comments on the 2021 proposed rile are due to CMS by October 5, 2020. For more information, please visit: