It has been a difficult 2020 with the ongoing presence of COVID 19 exhausting frontline healthcare entities and stalling the outpatient services. The pandemic has been a devastating historical event, but it has brought sweeping changes for 2021.
The Medicare Physician Fee Schedule was approved on Tuesday, December 1, 2020 and we had some surprises. There was a much anticipated, proposed Medicare conversion factor of 36.09 but the final conversion factor is reported as 32.41. This greatly affects the upcoming reimbursement associated with the Evaluation and Management Guidelines for new and established outpatient visits. Proposed reimbursement for the E&M codes 99202-99205 and 99211-99215 reflected an increase of seven to 10 percent for new visits and up to 40 percent for established visits. The new patient visit codes will now decrease in reimbursement with the final conversion factor and the established visits reimbursement will only increase by 11 percent to 15 percent.
The 2020 Medicare Physician Fee Schedule finalized the E&M overhaul, there were no changes to the documentation guidelines we have been discussing throughout the year with the release of the final fee schedule. An add-on code for visit complexity was confirmed, it is projected to be utilized at a high volume in addition to the listed E&M visit code. G2211 is the new add-on code and it can be utilized with new patient visits as well as established visits, it will add $15 of reimbursement to the visit encounter.
Practices should review their 2019 and 2020 CPT frequency to assess the bell curve for utilization of E&M in the past. The new guidelines could cause some shift. Begin tracking utilization and reimbursement in 2020 as providers become comfortable with the changes. Specialties generating a larger volume of new patients could see a loss in revenue compared to past years. Many commercial carriers waited for the CMS final fee schedule before making reimbursement decisions. Payer mix is always a factor in overall revenue and should be considered in benchmarking or analysis.
The Public Health Emergency is set to expire at the end of the calendar year and vaccines have been announced. Due to the increase in COVID cases, expansion of telehealth related to the Public Health Emergency was announced. An additional 114 CPT codes were added to telemedicine under the PHE period, but these codes will not be covered for telemedicine once the PHE period ends. Telephone visits 99441-99443 will also end when the PHE period ends but a new interim code G2252 is created for 2021 for a brief communication or “virtual check-in” it will be reimbursed at the same rate as the procedure code 99442.
The MIPS category weights are the same as proposed – 40 percent for quality, 20 percent for cost, 25 percent for promoting interoperability and 15 percent for improvement activities. However, note that the overall performance threshold that was going to drop to 50 points instead stays at 60 points for the 2021 reporting period. The expected overhaul of The Quality Payment Program named the MIPs Value Pathway was planned in 2019 for implementation in 2021 but it is delayed until 2022 due to the COVID emergency. The new program will drastically reduce the number of measures required to report.
Tammie Lunceford, CMPE, CPC serves as a Senior Healthcare Consultant with Warren Averett.
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