The much-anticipated proposed rule for the Medicare physician fee schedule was finally released on July 29, 2019. The bottom-line impact to urology for 2020-based changes to relative value units (RVUs) is a projected +1% additionally. The Centers for Medicare & Medicaid Services is projecting a minor 0.14% increase in the conversion factor from $36.04 to $36.09.
While the overall impact on the specialty for 2020 is minor, there are a few changes of note that we will address in this article. The more newsworthy information in the proposed rule surrounds changes to evaluation and management (E/M) coding effective Jan. 1, 2021.
First, we will address the changes for 2020.
MIPS changes. In the area of the Quality Payment Program (QPP), Medicare is proposing to increase the requirements for the Merit-based Incentive Payment System (MIPS) program. The threshold for physicians to avoid penalties for payments in 2022 will require a minimum score of 45 for performance in 2020, up from 30 in 2019. The percentage assigned to the Quality and Cost categories will be adjusted to 40% and 20%, respectively. The minimum score for exceptional performers will be raised to 80 points.
CMS did not change the eligibility requirements for reporting year 2020. The maximum penalty for those failing to meet MIPS requirements has been increased to –9%, up from –7%. Penalties and bonuses will be applied to payments in 2022 based on 2020 reporting. We encourage you to further review the proposed changes for the QPP program as CMS continues to change this program to increase the incentives to participate.
Supervision of advanced practice providers. CMS is proposing to modify regulation of physician supervision of physician assistants (PAs) to give PAs greater flexibility to practice more broadly in the current health care system in accordance with state law and state scope of practice. The proposal includes a provision that, in the absence of state law governing physician supervision of PA services, the physician supervision required by Medicare for PA services would be evidenced by documentation in the medical record of the PA’s approach to working with physicians in furnishing their services.
Physical therapy/occupational therapy benefits. CMS is proposing a change in per-beneficiary incurred expenses under physical therapy definitions. These benefit caps are no longer applied as limitations but as threshold amounts above which services require, as a condition of payment, inclusion of modifier –KX, and that use of modifier –KX confirms that the services are medically necessary as justified by appropriate documentation in the patient’s medical record. The definitional change should assist in providing services to patients receiving benefit from ongoing physical therapy-type services for pelvic floor rehabilitation. Functionally, you will need to continue to document medical necessity and improvement and use modifier –KX to indicate the services provided are medically necessary.
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