American College Of Surgeons - Inspiring Quality: Highest Standards, Better Outcomes

CMS Issues CY 2020 MPFS Proposed Rule

The Centers for Medicare & Medicaid Services (CMS) July 29 released the calendar year (CY) 2020 Medicare Physician Fee Schedule (MPFS) proposed rule. This rule, which CMS issues annually, updates payment policies, payment rates, and quality provisions for services furnished under the MPFS on or after January 1, 2020. CMS estimates a 0 percent impact on total allowed charges for general surgery services relative to its proposals for CY 2020.

The agency introduces various changes related to office/outpatient evaluation and management (E/M) visits, which would become effective in 2021. CMS proposes to align Medicare’s office/outpatient E/M coding with changes laid out by the CPT Editorial Panel for office/outpatient E/M visits, specifically: retain five levels of coding for established patients, and reduce the number of levels to four for new patients; eliminate history and physical as elements for E/M code selection and allow clinicians to choose the E/M visit level based on either medical decision making or time; and  create add-on codes for prolonged services and for primary care/non-procedural specialty care. CMS also proposes to increase the values for most office/outpatient E/Ms, per recommendations from the American Medical Association/Specialty Society Relative Value Scale Update Committee, but these increases will not apply to global surgery codes.

In addition, CMS proposes broad modifications to its review and verification of medical record documentation policies, such that certain nonphysician practitioners (such as physician assistants, nurse practitioners, clinical nurse specialists, and certified nurse midwives) could sign and date (that is, review and verify)—rather than redocument—notes made in the medical record by the attending physician or other members of a patient’s care team. The rule also includes proposals that would increase states’ authority to create and enforce laws governing the level of physician oversight for physician assistant (PA) services, and would revise existing Medicare regulations to specify that the physician supervision CMS requires for PA services could be evidenced by documentation in the medical record of the PA’s role in furnishing such services.

The American College of Surgeons is evaluating these and other proposals to determine the impact on surgery and will submit comments to CMS. The proposed rule is available for public review, along with a fact sheet on its payment provisions. Contact with questions.

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