The 2020 Medicare Physician Fee Schedule and Quality Payment Program proposed rule was released by the Centers for Medicare & Medicaid Services (CMS) on August 3.

View the AUA’s easy reference on how the proposed rule could affect urology offices.

CMS proposes a 2021 conversion factor of $32.2605, down from $36.0896 in 2020. The impact tables below identify some of the most common urology procedures in the office and facility setting. The tables display the difference in payment from 2020 to 2021 proposed values in RVUs for physician work, practice expense and malpractice. Please note that these are based on national rates, and payment adjustments will be applied based on geographical locations.

Please note that some procedure codes had an increase in the RVUs while other codes had a decrease in RVUs when performed in the office (non-facility) setting. This resulted in both payment increases and decreases from 2020 to 2021. For example:

• Code 52000 Cystoscopy, has a payment increase of 8.34 percent in the office setting
• Code 52287 Cystourethroscopy, with chemodenervation bladder has an increase of 4.01 percent in the Office setting
• Code 52204 Cystourethroscopy, with biopsy(s) has a decrease of 0.02 percent
• Code 52332 Cystoscopy with stent insertion has a decrease of 5.09 percent

There was a decrease in RVUs for procedure codes when performed in the Facility (Hospital) setting.

Click each thumbnail below to view the conversion tables.

CY 2021 Outpatient Evaluation and Management Changes and the Budget Neutrality Implications

CMS proposed minor changes to the outpatient evaluation and management (E/M) policies finalized in last year’s Physician Fee Schedule rule (PFS). On January 1, 2021, the majority of outpatient E/M RVUs will increase and the associated documentation requirements will be simplified as long as no additional changes are made in this year’s final rule. However, the increases to outpatient E/M services may not appear as large as anticipated because of the requirement that all fee schedule changes be budget neutral. With outpatient E/M services accounting for approximately 20 percent of fee schedule services, the conversion factor decreased by almost $4 from $36.0896 to $32.2605 and the majority of this decrease was to account for the changes in this single code family.

While CMS is estimating that all of the policies in the CY 2021 PFS proposed rule will result in an 8 percent increase in reimbursement for urologists, it is clear that an individual provider’s increase will vary based on their case mix. For the Evaluation and Management (E/M) codes, CMS has decreased the payment for the New Office Visit codes, while increasing the payments for the Established Office Visit codes, with the exception of CPT 99211 (the lowest established visit code).

Policies slated to go into effect in 2021 remain unchanged, though CMS has revised how it will consider total time for services, adding the pre-, intra-, and post-service times rather than using the RVS Update Committee (RUC) times to be consistent with other services.

Additional Points of Interest

The AUA is also reviewing other changes in the proposed rule, including:

• Valuation of specific urology codes
• Quality Payment Program modifications, including Merit-based Incentive Payment System (MIPS) changes
• Updates and changes to the Open Payments program
• Changes in physician supervision requirements for physician assistants
• Telehealth changes, including the proposed addition of codes to the telehealth services list and the creation of another list of temporary codes that could be delivered via telehealth to Medicare beneficiaries

The AUA will monitor the changes and report important issues in the near future.

View the Proposed Rule  View the Fact Sheets

CMS is accepting comments on the proposed rule through October 5, 2020.

The AUA will be submitting comments. Any organization, individual physician or citizen can comment, as well. In commenting, please refer to file code CMS-1734-P.

How to Comment

Comments, including mass comment submissions, must be submitted in one of the following three ways (please choose only one of the ways listed):

1. Submit electronic comments on this regulation. Follow the "Submit a comment" instructions.
2. Mail written comments to the following address ONLY:
   Centers for Medicare & Medicaid Services
   Department of Health and Human Services
   Attention: CMS-1734-P
   P.O. Box 8016
   Baltimore, MD 21244-8016

Please allow sufficient time for mailed comments to be received before the close of the comment period.

3. By express or overnight mail. You may send written comments to the following address ONLY:
   Centers for Medicare & Medicaid Services
   Department of Health and Human Services
   Attention: CMS-1734-P
   Mail Stop C4-26-05
   7500 Security Boulevard
   Baltimore, MD 21244-1850