With telehealth provisions for Medicare in 2021, physician fee schedule laws allow for policy and payment adjustments. A draft regulation to resolve improvements to the Medicare Physician Fee Schedule (MPFS) and other Medicare Part B payment plans for 2021 and beyond was released by the Centers for Medicare & Medicaid Services (CMS) on August 3.
Turning Permanent Emergency Telehealth Coverage
In response to the Public Health Emergency (PHE) for the COVID-19 pandemic, CMS has begun immediate emergency rule-making to expand the number of providers on the Medicare Telehealth Services list, including Communication Technology-Based Services (CTBS). It is now considered which programs on the Medicare Telehealth list will start.
Care Management Services Code Refinements
CMS is proposing code optimization for Remote Physiologic Monitoring (RPM), Transitional Care Management (TCM), and psychiatric collaborative care model (CoCM) systems to increase accountability for care management services.
New Payment Rates for Immunization Administration Services
In the latest COVID-19 pandemic associated PHE, CMS says it’s clear that reliable recipient access to vaccines is crucial for public health. In the final rule of the CY 2020 PFS, CMS agreed that ensuring sufficient resource costs is reflected in assessing the immunization administration facilities used to provide vaccines in the public interest.
Increasing the Value of Services
CMS is proposing to expand specific programs similar to or include E- /- M visits to office patients, such as prenatal care packages, ED appointments, and PT and OT assessment services. CMS has finalized new values for CPT® codes 99202 through 99215 and assigned RVUs to the new office/outpatient E/M prolonged visit code as well as the new HCPCS Level II code GPC1X. These evaluations were finalized with an effective date of January 1, 2021.
1-Teaching Physician and Resident Moonlighting Policies
In the March 31 COVID-19 Interim Final Rule with Consultation Period (IFC) and the May 1 COVID-19 IFC, CMS adopted multiple regulations relating to MPFS reimbursement for teaching physicians’ services, including residents and the resident moonlighting control. CMS is debating whether these policies should be temporarily extended —to suggest, if the PHE ends in 2021, those policies may be extended to December 31, 2021, allowing for a transitional period before reverting to the status quo policy — or making it permanent.
Supervision of Diagnostic Tests by Certain NPPs
At the COVID-19 PHE on May 1 COVID-19 IFC, CMS developed an interim policy allowing Physician Assistants (PAs), Nurse Practitioners (NPS), and some other NPPs to supervise diagnostic tests. By amending the rules, CMS is now planning to make those changes permanent.
Pharmacists Offering Services Incident to Physicians’ Services
CMS reiterates the clarification given in the May 1 COVID-19 IFC that pharmacists come under §410.26 of the legislative concept of auxiliary workers according to our regulations. As such, pharmacists can provide incidental services to the billing physician or NPP’s services under the correct level of supervision if payment for the services is not made under Part D of the Medicare benefit. It involves delivering emergency care to the billing physician or NPP care and upholding the state scope of practice and the pharmacist’s applicable state law.
Extensive Screenings for Seniors
CMS aims to incorporate Section 2002 of the SUPPORT Act by introducing legislative language to existing Initial Preventive Physical Examination (IPPE) and Annual Wellness Visit (AWV) legislation to specifically include screening for possible drug use disorders and a study of current opioid prescriptions.
Summary of the 2021 MPFS Proposed Rule
In this new proposed regulation, CMS aims to set up Relative Value Units (RVUs) for the MPFS for a Calendar Year (CY) 2021 to ensure that payment systems are revised to reflect changes in the medical profession and the relative value of services, as well as changes in the law. The new regulation also contains reviews and guidelines for other payment plans under Medicare Part B. Check the proposed rule for codes or keywords specific to your practice to identify proposed code changes that could impact your practice.
