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It’s the moment every geriatrics policy wonk has waited for… 

The Centers for Medicare and Medicaid Services (CMS) this past Friday issued the final rule for the 2020 Medicare Physician Fee Schedule (MPFS). As a quick refresher, the MPFS outlines how physicians and other qualified health care professionals (QHPs) will be paid by Medicare in the next calendar year. The AGS submitted comments on a proposal for the rule in late September. You can see what we had to say in those early days here (if you’re looking for even more background on why commenting on the MPFS is a priority here at the AGS, check out our JAGS article from 2018).

The final rule is 2,400+ pages long, so our experts are already hard at work churning through what’s been finalized. We’re planning a winter webinar so we can help you prepare for these changes. But everyone deserves a teaser trailer, right—so here’s what has us #AGSHappy and #AGSIntrigued based on our preliminary read of the 2020 MPFS Final Rule…

In general, we’re #AGSHappy to see continued work to improve Medicare payment policy and address instances when policies or requirements have created undue administrative burden (including recent changes to finalize proposed updates to the outpatient office visits codes).

We also appreciate CMS finalizing proposals addressing gaps in coding and payment for care management services.

So what has us #AGSIntrigued (with some #AGSProud highlights along the way…)?

• Finalized Changes to E/M Coding (and a bump in E/M visit values thanks to input from the AGS): CMS finalized extensive changes to the office/outpatient evaluation and management (E/M) visits codes. These changes apply to office visits only and will be implemented in 2021. E/M services are the “bread and butter” of geriatrics (and were a central point of concern for the AGS last year, when CMS proposed collapsing E/M coding in a way that would have jeopardized care for us all as we age). Working as part of a coordinated effort spearheaded by the American Medical Association (AMA), the AGS provided extensive input to help build a better system. The new changes outlined in the final rule (and set to take effect in 2021) would:
  • Retain 5 E/M levels of coding for established patients but reduce the number of E/M levels to 4 for new patients. The code definitions have also been revised.
  • Revise the time and medical decision-making process, and require performing history and exam only as medically appropriate.
  • Allow clinicians to choose the E/M visit level based on either medical decision making or time.
  • Adopt a new add-on CPT code for prolonged services.
  • Adopt the AMA RVS Update Committee (RUC)-recommended values for E/M visits, which would increase payment for these codes.

    Highlight: The AGS played a key role in the survey of these codes, which made this increase possible.

• Increased Payment for TCM (Effective January 1, 2020): CMS is increasing payment for Transitional Care Management (TCM) services, which reimburse QHPs for coordinating Medicare beneficiaries’ transitions from inpatient to outpatient settings. CMS is also promoting greater use of TCM by removing several services that, if reported, preclude use of TCM.

  Highlight: The AGS was instrumental in getting TCM recognized by CMS in 2013.

• Revisions to CCM Services (Effective January 1, 2020): CMS also finalized several revisions to Chronic Care Management (CCM) services and created a new pair of codes that match CCM for persons with a single serious condition. These new rules no longer require revision of the care plan to report Complex CCM. There is a new "G code" that can be used when CCM by clinical staff is 40 minutes or longer. There are two new G code services to reimburse clinicians for providing care management to patients with a single serious, high-risk condition: One for physician time similar to 99491 and one for staff time similar to 99490.

  Highlight: CCM services were recognized for reimbursement by Medicare in 2015 thanks in part to hard-fought victories at the AGS. You can learn more here.

• Online digital E/M services (Effective January 1, 2020): For established patients, CMS will now pay for online visits that do not occur proximate to an E/M face-to-face service. All non-face-to-face services have been made easier to use by CMS allowing a once-a-year beneficiary authorization.

• Final Rule
• Physician Fee Schedule Fact Sheet
• Quality Payment Program Fact Sheet