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Regs and Eggs - August 15, 2019

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Diving into the Regs: Highlights of the 2020 Medicare Physician Fee Schedule

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As discussed in my last blog, the Centers for Medicare & Medicaid Services (CMS) recently released major regs that impact emergency medicine. Of these regs, the Calendar Year (CY) 2020 Medicare Physician Fee Schedule (PFS) and Quality Payment Program (QPP) Proposed Rule has the greatest impact on you since it includes proposals that affect Medicare physician payments and the Merit-based Incentive Payment System (MIPS), the main physician quality reporting program in Medicare. ACEP is currently reviewing the proposed rule and will be drafting comments on the rule over the next several weeks.

It is important to note that these are only proposed policies. CMS will be releasing a final rule in early November that finalizes policies for 2020.

You can read my comprehensive summary of the proposed rule here, but here are the highlights:

  • Increasing the Value of ED E/M Services: CMS is proposing an increase in the value of emergency department (ED) Evaluation/Management (E/M) services, the most commonly billed services by emergency physicians. For more information about the ED E/M proposed changes, please click here.
    • For 2021, CMS is proposing an increase to the other office and outpatient E/M services, which could lower the eventual payments to ED E/M codes because of required budget neutrality in Medicare.
  • Reducing Documentation Burden: CMS is proposing broad flexibility for re-documenting information already included in the medical record. Specifically, CMS is proposing to allow the physician, the physician assistant, or the advanced practice registered nurse who delivers and bills for their professional services to review and verify, rather than re-document, information included in the medical record by physicians, residents, nurses, students, or other members of the medical team.
  • Adding a New Benefit for Opioid Use Disorder Coverage: CMS is proposing to add a new benefit for covering treatment services delivered by an opioid treatment program (OTP). OTPs do not include EDs, as they must be certified by the U.S. Substance Abuse and Mental Health Services Administration (SAMHSA) and meet certain accreditation standards. CMS is also proposing to establish bundled payments for the overall treatment of Opioid Use Disorder (OUD) and is seeking comment on possibly reimbursing medication-assisted treatment (MAT) in the ED in the future.
  • Changing the definition of “hospital-based” for the Promoting Interoperability (EHR) category of MIPS: Currently, clinicians who are considered “hospital-based” as individuals are exempt from the Promoting Interoperability category of MIPS. However, if individual clinicians decide to report as part of a group, they lose the exemption status if even a single group member does not meet the definition of “hospital-based.” ACEP has repeatedly argued that this is unfair as it penalizes hospital-based clinicians who work in multi-specialty groups. As a result of our advocacy, CMS is proposing to modify this policy by exempting groups from the Promoting Interoperability category of MIPS as long as 75 percent of individuals in the group meet the definition of hospital-based.
  • Increasing the Performance Threshold under MIPS: CMS is proposing to increase the MIPS performance threshold—the point total a clinician must exceed to be eligible for a payment bonus—from 30 points in 2019 to 45 points in 2020 and to 60 points in 2021. CMS has an additional bonus on top of their regular performance threshold and is proposing to increase the threshold for this additional bonus from 75 points in 2019 to 80 points in 2020.
  • Adding new Qualified Clinical Data Registries (QCDR) Requirements: CMS proposes numerous new requirements for both 2020 and 2021 for QCDRs that will have a direct impact on ACEP’s own QCDR, the Clinical Emergency Data Registry.

Until next week, this is Jeffrey saying, enjoy reading regs with your eggs!

jeff headshot.PNGIf you have any questions or want to weigh in on other regulatory items, feel free to email me: jdavis@acep.org.

Jeffrey Davis is the Director of Regulatory Affairs at the American College of Emergency Physicians (ACEP). He manages ACEP’s formal response to federal policies and works with federal agencies and other stakeholders to help advance ACEP’s federal affairs agenda. Prior to that, Jeffrey worked in the Budget Office at the U.S. Department of Health and Human Services for nearly eight years. Jeffrey came to the Government as a Presidential Management Fellow, and in his position in the Budget Office, he advised top level officials on major budgetary and policy considerations within Medicare and prepared detailed analyses of Medicare regulations and legislation. Jeffrey has a Masters of Science in Health Policy and Management from the Harvard T.H. Chan School of Public Health and a Bachelors of Arts degree from Duke University.

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