The Physician Fee Schedule final rule outlines new 2020 performance year Medicare requirements for small practice providers

On November 1, 2019 the Center for Medicare and Medicaid services (CMS) released the 2020 Physician Fee Schedule final rule. The final rule outlines Medicare policies for small practice providers and establishes eligibility guidelines for the various programs supported. Below you will find the finalized proposals the Practice Fusion regulatory team believes are most important for small practice providers to be aware of as the January 1, 2020 implementation date of the 2020 Physician Fee Schedule Final rule approaches.

Evaluation and management coding

To combat the growing problem of clinician burden and the resulting burnout, updates to evaluation and management billing requirements have been made. The number of levels associated with new patient office and outpatient evaluation and management visits has been reduced to four. Additionally, CMS has chosen to revise code definitions as part of a coordinated effort to pay for each level of service rather than use the previously blended rates. These revised definitions will allow clinicians to choose the evaluation and management visit level based on time or medical decision making.

The supervision of physician assistants

In another effort to further reduce clinician burden, CMS has redefined the relationship required to substantiate the practice of a physician assistant. Moving forward, to prove physician supervision of the physician assistant, there will be required documentation to illustrate the physician assistant’s role within the larger practice and who is responsible for overseeing their work.

Medicare will now cover opioid use disorder treatment services furnished by opioid treatment programs (OTPs)

Under the rulings finalized in the SUPPORT Act in 2018, beginning January 1, 2020 Medicare must begin supporting numerous opioid use disorder treatment services, including substance use counseling, group therapy, and FDA approved opioid agonist and antagonist medications used for treatment. Bundled payment rates, based on the medication given to patients during a one- week treatment period, will also be available for OTPs. In order to be eligible for the bundled payment rates provided by CMS, OTPs must first enroll in Medicare.

To increase the access to and quality of patient care for those suffering from opioid use disorder, the following Health Care Common Procedural Code System (HCPCS) codes have been added to the telehealth services list: G2086, G2087, and G2088. These three codes will be used for Medicare to identify bundled episodes of care for the treatment of opioid use disorder. This will enable greater coordination and greater access to care for the beneficiary.

Increasing care management services

To enhance the value of beneficiary care, CMS has finalized a proposal to increase payment for transitional care management services. These are the services that are provided to Medicare beneficiaries post discharge from an inpatient stay, and under certain circumstances outpatient stays. To better classify the care delivered to beneficiaries, CMS has also created a Medicare specific code that will be used to identify encounters where additional time is spent with the patient beyond the basic 20 minutes that are currently allowed in the coding schema for care management services classified as chronic. The first 20 minutes clinical staff spend performing chronic care management services may be billed under CPT code 99490. The remainder of the time spent with the patient performing chronic care management services will be billed in 20- minute increments under the CPT code G2058.

Approaching January 1, 2020

As the implementation date of the above-mentioned pieces of the Physician Fee Schedule Final Rule approaches, compliance and awareness of these changes will be a necessary factor for a small practice provider’s success. While the changes may seem numerous and complex, Practice Fusion providers can be assured the regulatory team is taking the necessary steps to ensure all providers are prepared for the coming performance year.