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Final Rule Released for 2020 Medicare Physician Fee Schedule, Quality Payment Program
The Centers for Medicare & Medicaid Services released the CY 2020 Medicare Physician Fee Schedule and Quality Payment Program final rule on November 1. The rule implements a number of provisions in the proposed rule that were supported by the AUA, including an increase in the conversion factor for 2020 and an increase in allowable charges for urology. Read the AUA’s comment letter on the proposed rule.
The regulation also finalizes important changes to evaluation and management (E/M) that would go into effect in 2021. These E/M changes reflect the collective feedback of top medical groups around the country, including the AUA and the American Medical Association (AMA). ( Read more.) CMS will not apply the outpatient E/M visit increases to 10- and 90-day global services, and it did not modify its stance on physician supervision requirements for physician assistants. We were successful in our request for CMS to increase the practice expense for the Percutaneous Neuro Test Stimulation Kit (SA022) supply.
The tables below outline a number key provisions in the final rule of interest to urologists. For more information about the final rule, please contact PaymentPolicy@AUAnet.org.
| 2020 Proposed Medicare Fee Schedule | |||
|---|---|---|---|
| AUA Position | Next Steps | ||
| Proposed Rule | Final Rule | ||
| Conversion Factor |
2020 Final: $36.09 |
||
| Specialty Impact |
1% increase in allowable charges for urology (overall 0 percent increase in work RVUs, 1 percent increase in practice expense) |
||
| Evaluation & Management (E/M) Coding |
CMS will not consolidate E/M codes and instead will implement revised code definitions developed by the AMA CPT Editorial Panel that have an effective date of January 1, 2021. According to CMS, the changes will lead to an 8 percent increase for urology (4 percent increase in Work RVUs, 4 percent increase in practice expense). |
||
| E/M Payments |
CMS will eliminate CPT code 99201, and will retain separate payment for individual services as revised by AMA CPT Editorial Panel, including the adoption of values for outpatient codes for new patients (99202-99205) and established patients (99211-99215). CMS is implementing all RUC-recommended work RVUs and times for these codes. |
||
| Global Surgical Packages |
CMS has rejected the RUC’s recommendation to apply the outpatient E/M visit increases to 10- and 90-day global services. |
||
| Physician Supervision Requirements for Physician Assistants |
CMS will grant physician assistants flexibility to practice in accordance with state law requirements. In the absence of state law, the physician supervision requirement can be met by “documentation in the medical record of the PA’s approach to working with physicians in furnishing their services.” |
||
Read our blog post for more detailed information about E/M payments under the 2020 proposed fee schedule rule.
| Valuation of Specific Urology Services | ||||
|---|---|---|---|---|
| AUA Position | Next Steps | |||
| Proposed Rule | Final Rule | |||
| CPT 64561 – SA022 Kit (Practice Expense) |
Recommended price in final rule: $413.24 (up from $114.52 in proposed rule) |
|||
| Drug Delivery Implant Procedures | ||||
| CPT 11980 |
CMS will implement RUC recommendations |
|||
| CPT 11981 |
CMS 2020 Work RVU: 1.14 |
|||
| CPT 11982 |
CMS 2020 Work RVU: 1.34 |
|||
| CPT 11983 |
CMS 2020 Work RVU: 1.91 |
|||
| Cystourethroscopy Insertion Transprostatic Implant | ||||
| CPT 52441 |
CMS 2020 Work RVU: 4.00 |
|||
| CPT 52442 |
CMS 2020 Work RVU: 1.01 |
|||
| Orchiopexy | CPT 54640 |
CMS will implement RUC-recommended work RVU of 7.73 and direct practice expense inputs |
||
| Urography | CPT 74425 |
CMS will implement RUC-recommended work RVU of 0.51, time of 24 minutes and direct practice expense inputs |
||
| Biofeedback Training | ||||
| CPT 908XX |
CMS will implement RUC-recommended work RVU of 0.90 and will refine equipment time for the power table code (EF031) equipment code included in the service |
|||
| CPT 909XX |
CMS will implement the RUC-recommended work RVU of 0.50 and designate these services as “sometimes therapy” procedures |
|||
| 2020 Quality Payment Program | |||
|---|---|---|---|
| AUA Position | Next Steps | ||
| Proposed Rule | Final Rule | ||
| MIPS Value Pathways initiative |
CMS will implement a new MIPS Value Pathways framework that would connect measures and activities across the four MIPS performance categories. The framework would go into effect in 2021. |
||
| MIPS Performance Thresholds |
CMS will increase the performance threshold from 30 points in 2019 to 45 points in 2020 and 60 points in 2021. The additional performance threshold for exceptional performance will be 85 points for both 2020 and 2021. |
||
| Consumer Assessment of Healthcare Providers and Systems (CAHPS) Survey Expansion |
CMS sought comment on expanding the CAHPS survey for MIPS to those participating individually, but the final rule does not address this issue. |
||
About the Proposed Rule
CMS released the 2020 Medicare Physician Fee Schedule and Quality Payment Program proposed rule on July 29, 2019. The AUA submitted its comment letter to CMS on September 24.
The impact tables below identify some of the most common urology procedures in the office and facility setting, and display the difference in payment from 2019 to 2020 proposed values in RVUs for physician work, practice expense and malpractice.
| Facility | Non-Facility |
 |
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