Physician Fee Schedule and Quality Payment Program CY2020 Proposed Rule - Make Your Revenue Smarter

As part of CMS’s annual changes to the Medicare Physician Fee Schedule and Quality Payment Program, the agency’s proposals are aimed at reducing burden, recognizing clinicians for the time they spend with patients, removing unnecessary measures and making it easier for them to be on the path towards value-based care. 

Last year, the Trump Administration finalized historic changes to simplify billing and coding requirements for certain office-based visits known as Evaluation and Management (E/M) services, responding to longstanding criticism that they were burdensome and overly complicated. Those changes, the first to the E/M framework in more than 20 years, gave clinicians new flexibility to consider time with the patient or medical decision-making in how they code an E/M visit, so they could focus more closely on what is clinically relevant and medically necessary for the patient.

The proposed changes in this year’s rule would build on these policies by paying clinicians across all specialties for the time they spend treating the growing number of patients with greater needs and multiple medical conditions, through increasing the value of E/M codes for office/outpatient visits and providing enhanced payments for certain types of visits. CMS is investing in the critical thinking required to evaluate a patient, which will help improve outcomes. This is especially important to certain specialists that spend significant time managing patients with multiple co-morbidities, such as diabetes and heart disease.

CMS is also taking steps to help clinicians better manage chronically ill patients, particularly during their transition from hospital to home. The proposed rule would increase payments to practitioners for time spent on care management after a patient leaves the hospital ensuring proper follow-up and continuity of care for patients. For the first time, CMS is proposing to pay for care management services for patients with a single, high-risk chronic condition such as diabetes or high blood pressure. CMS is also proposing to pay clinicians more for additional time spent on care management activities for patients suffering from multiple chronic conditions. These steps would address drivers of healthcare costs and ensure a sustainable safety net for vulnerable patients.

In addition to the Physician Fee Schedule, CMS is proposing changes to improve the Quality Payment Program by streamlining the program’s requirements with the goal of reducing clinician burden. Today’s proposal includes a new, simple way for clinicians to participate in our pay-for-performance program, the Merit-based Incentive Payment System (MIPS). This new framework called the MIPS Value Pathways (MVPs), beginning in the 2021 performance period, would move MIPS from its current state, which requires clinicians to report on many measures across the multiple performance categories, such as Quality, Cost, Promoting Interoperability and Improvement Activities, to a system in which clinicians will report much less. Under MVPs, clinicians would report on a smaller set of measures that are specialty-specific, outcome-based, and more closely aligned to Alternative Payment Models (APMs) – new approaches to paying for care through Medicare that incentivize quality and value.

In addition, MVPs would allow CMS to provide more data and feedback to clinicians. Having access to this information helps clinicians quickly identify strengths in performance as well as opportunities for continuous improvement in order to deliver the best outcomes possible for patients.

This proposed rule advances CMS’s goal to combat the opioid epidemic with new Medicare coverage to pay opioid treatment programs (OTPs) for delivering Medication-Assisted Treatment (MAT) to people with Medicare suffering from Opioid Use Disorder (OUD). Opioid Treatment Programs (OTPs) are programs or providers that provide a range of services to people with opioid use disorder, including medication-assisted treatment and counseling. OTPs must be accredited by the Substance Abuse and Mental Health Services Administration (SAMHSA). One of the Agency’s top priorities is to fight the opioid crisis by increasing access to evidence-based treatment for opioid use disorder. CMS is also proposing to make a new monthly bundled payment to practitioners for management and counseling involving MAT for patients with opioid use disorder. Similar to the new payment to opioid treatment programs, this bundled payment to clinicians would cover care activities like overall patient management, care coordination, individual and group psychotherapy, and substance-use counseling, increasing patient access to evidence-based services that support OUD recovery.

Public comments on the proposed rules are due by September 27, 2019.

For a fact sheet on the CY 2020 Physician Fee Schedule proposed rule, please visit: https://www.cms.gov/newsroom/fact-sheets/proposed-policy-payment-and-quality-provisions-changes-medicare-physician-fee-schedule-calendar-year-2

For a fact sheet on the CY 2020 Quality Payment Program proposed rule, please visit: https://qpp-cm-prod-content.s3.amazonaws.com/uploads/594/2020 QPP Proposed Rule Fact Sheet.pdf

To view the CY 2020 Physician Fee Schedule and Quality Payment Program proposed rule, please visit: https://www.federalregister.gov/documents/2019/08/14/2019-16041/medicare-program-cy-2020-revisions-to-payment-policies-under-the-physician-fee-schedule-and-other

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