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COVID-19 Information for AAOMS Members: Updates and Resources

Medicare Physician Fee Schedule final rule issued

January 11, 2021

CMS issued the 2021 Medicare Physician Fee Schedule (MPFS) Final Rule in the Dec. 28 Federal Register and published on its website a fact sheet summarizing the rule and providing tables and addendums mentioned in the rule. The rule finalized a 10.2 percent drop in the conversion factor from $36.09 in 2020 to $32.41 in 2021.

However, President Trump on Dec. 27 signed the COVID-19 relief package into law that included a provision delaying the implementation of the add-on HCPCS code G2211. The funds originally allocated for reimbursement by CMS for the new HCPCS code will instead be spread across all specialties and services and will increase the finalized conversion factor by 8 percent from $32.41 to $34.89. The estimated impact to the OMS is 2 percent versus the original finalized conversion factor of -4 percent. This is due to policy changes specifically related to the budget neutrality adjustment to account for changes in relative value units (RVUs) in addition to CMS proposals to increase valuation for specific services (e.g., E/M office/outpatient visits).

Additional highlights include:

  • Extending the telehealth and licensing flexibilities beyond the public health emergency (PHE) by adding a selection of telehealth codes on an interim or permanent basis.
  • Expanding scope of practice to relax specific restrictions for non-physicians in rural areas via telehealth.
  • Revising the definition of direct supervision of residents in a teaching setting to specify the teaching physician must be present in-person or virtually through audio/video real-time communications technology during the key portion of the service through the end of the PHE or Dec. 31, 2021.
  • Establishing a new HCPCS code, G2212, which will require the E/M visit to exceed the maximum time of 99205* or 99215* to be reported. G2212 is intended to be reported when a maximum of 15 minutes of additional time has been met after the total time of the E/M service.
  • Adding a new virtual check-in code, G2252, to account for additional time (11-20 minutes) used to reflect the resources associated with a longer service delivered via synchronous communication technology, which can include audio-only communication.
  • Delaying the Quality Payment Program’s MIPS Value Pathways overhaul by at least a year to allow for a gradual implementation timeline and an introduction to the Alternative Payment Model Performance Pathway (APP).
  • Stipulating the Medicare Shared Savings Program will sunset the CMS Web Interface and instead require data to be submitted via the APP and based on the fourth-quarter list of assigned beneficiaries.

CMS also is implementing on an interim basis two final rules with comment – one on coding and payment for PPE as a bundled service and another on coding and payment of virtual check-in services. AAOMS will provide a full summary of changes impacting the OMS later this month at AAOMS.org.

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