The much-anticipated release of the 2020 Physician Fee Schedule Proposed Rule

On Monday, July 29th the Centers for Medicare and Medicaid Services released the much anticipated 2020 Physician Fee Schedule proposed rule. The 2020 Physician Fee Schedule proposed rule includes requirements that will go into effect on January 1, 2020. These requirements concern topics such as the Quality Payment Programs, Medicare Part B payment policies, the Medicare Shared Savings Program, and the Medicaid Promoting Interoperability program. Other topics are also addressed, such as the establishment of an ambulance data collection system and the Medicare enrollment of opioid treatment programs. The regulatory team at Practice Fusion has provided a summary below of some of the key proposals providers and eligible professionals should be aware of in the 2020 Physician Fee Schedule proposed rule.

Quality Payment Programs in 2020

As has been the trend for every subsequent year of the Merit-Based Incentive Payment System (MIPS), performance requirements, categories, and weighting have been modified for the upcoming performance year. Eligible clinicians will be required to meet a 45-point performance threshold to avoid a negative payment adjustment and those eligible clinicians wishing to meet the exceptional performance threshold will be required to earn 80 points. The quality performance category has been reweighted to 40% and the cost performance category has been reweighted to 20%.

In 2021 CMS will introduce a new program, MIPS Value Pathways (MVPs), which offers clinicians the opportunity to participate in the MIPS program by reporting on a smaller set of specialty-specific, outcome-based measures. MVPs will be similar to Alternative Payment Models in their structure.

Medicaid Promoting Interoperability

During the 2020 performance year, eligible professionals participating in the Medicaid Promoting Interoperability program who have previously demonstrated meaningful use will report eCQMs on a 274-day period. This is an increase from the 90-day continuous period required for 2019. This 274-day period must fall within CY 2020. In doing this CMS hopes eligible professionals will attest to their state Medicaid agency as early as October 1, 2020.

Medicare Shared Savings Program

In the 2020 performance year the Shared Savings quality measure set will be in line with the MIPS Web Interface measure set. Additionally, there will be a change to the claims-based measures under the Shared Savings Program.

Rate Setting and Conversion Factor

To account for changes in relative value units (RVUs,) there will be a budget neutrality adjustment. In 2020, the Physician Fee Schedule conversion factor will increase to $36.09, a $0.05 increase from the 2019 Physician Fee Schedule conversion factor of $36.04.

Evaluation and Management (E/M) Services Payment

The previous changes to E/M code defined in the 2019 Physician Fee Schedule have been delayed until January 1, 2021. These changes would have blended rates for office visits levels 2-4. Moving forward, CMS has chosen to work with the American Medical Association (AMA) on improving these changes, adopting a new framework based on their educated and informed guidelines.

Opioid Use Disorder Treatment Services Furnished by Opioid Treatment Programs will soon be covered by Medicare

As a result of the Substance-Use Disorder Prevention that Promotes Opioid Recovery and Treatment for Patients and Communities Act (SUPPORT Act), Section 2005, opioid use disorder (OUD) treatment services will be covered under a Medicare Part B benefit beginning January 1, 2020. Bundled payment rates, based on the intensity of medication used and the duration of time for which the medication is dispensed will be utilized to pay for the opioid treatment programs (OTPs).

Moving Forward

Per typical rulemaking protocol, CMS has asked that those wishing to submit comments on the 2020 Physician Fee Schedule Proposed Rule do so by September 27, 2019. Comments may be submitted electronically, to www.regulations.gov, by regular mail, and by express or overnight mail. Practice Fusion will be closely reviewing and providing comments on the Physician Fee Schedule proposed rule to CMS. We are pleased to provide initial insight on the changes that will affect our providers and practices in the new year.

• A fact sheet on the 2020 Quality Payment Programs has been provided by CMS and can be accessed here.
• The 2020 Physician Fee Schedule proposed rule in full can be accessed here.