The much-anticipated release of the 2020 Physician Fee Schedule Proposed Rule

By Tom Pasquariello, PharmD, BCPS, BCMAS, PRS

Blog Posts - 05 August 2019


On July 29th the Centers for Medicare and Medicaid Services (CMS) released the much anticipated 2020 Physician Fee Schedule proposed rule, slated to go into effect on January 1, 2020. The 2020 Physician Fee Schedule proposed rule includes requirements and proposals that affect members across the entire medical community, including clinicians, health plans, and patients. These requirements concern topics such as the Quality Payment Programs, Medicare Part B payment policies, the Medicare Shared Savings Program, and the Medicaid Promoting Interoperability program, and Medicare coverage of opioid treatment programs. The Veradigm regulatory team has provided a summary below of some of the key proposals that providers and eligible professionals should be aware of in the 2020 Physician Fee Schedule proposed rule.

2020 Policies Impacting Clinicians

Beginning in CY 2020 CMS has proposed several policies aimed at improving clinician experience. These policies include:

  • The introduction of a new program, MIPS Value Pathways (MVPs) which will offer clinicians the opportunity to participate in the MIPs program, but allow them to focus on a smaller set of specialty-specific, outcome-based measures. MVPs will be similar in structure to Alternative Payment Models.
  • The introduction of a 274-day eCQM reporting period for eligible professionals participating in the Medicaid Promoting Interoperability program (Formerly Medicaid Meaningful Use), who demonstrated Meaningful Use in a prior year. This 274-day period must fall within the 2020 calendar year. In doing this CMS hopes it will enable eligible professionals to attest to their state Medicaid agency as early as October 1, 2020.
  • Alignment of the Medicare Shared Savings Program the quality measure set with the MIPS Web Interface measure set. This change seeks to reduce confusion and promote consistency between the Medicare programs.

2020 Policies Impacting Health Plans

For the 2020 performance year CMS has proposed modified policies for Relative Value Units (RVUs) and Evaluation and Management (E/M) coding. Changes include:

  • To account for changes in relative value units (RVUs), the 2020 Physician Fee Schedule conversion factor will increase from $36.04 to $36.09.
  • The previously proposed payment changes to E/M coding defined in the 2019 Physician Fee Schedule have been delayed until January 1, 2021. These changes would have blended rates for office visits levels 2-4. Looking forward, CMS has decided to work with the American Medical Association (AMA) on improving these changes, adopting a new framework based on their guidelines.

2020 Policies Impacting Patients

CMS expands Medicare Part B coverage of opioid use disorder (OUD) treatment services.

  • This new benefit, which begins January 1, 2020, was a requirement of the Substance Use Disorder Prevention that Promotes Opioid Recovery and Treatment for Patients and Communities Act (SUPPORT Act).
  • Reimbursement of opioid treatment programs (OTPs) will be a bundled payment rate based on the intensity of medication used and the duration of time for which the medication is dispensed.

It is important to reiterate that the policies put forth in the Physician Fee Schedule are proposed and not yet final. CMS will modify and finalize these policies based on stakeholder input.

CMS has requested those wishing to submit comments on the proposed policies do so by September 27, 2019. Comments may be submitted electronically, to www.regulations.gov, by regular mail, and by express or overnight mail.

Veradigm will be closely reviewing and providing comments on the Physician Fee Schedule proposed rule to CMS. Veradigm is pleased to provide initial insight on the changes that will affect providers, health plans, and patients in the new year.

  • A fact sheet on the 2020 Quality Payment Programs has been provided by CMS and can be accessed here.
  • Those wishing to access the 2020 Physician Fee Schedule proposed rule may do so here.