The Centers for Medicare and Medicaid Services (CMS) filed the unpublished and proposed Medicare Physician Fee Schedule (MPFS) rule for calendar year 2020 on July 29, 2019. The proposed rule is scheduled to be published in the Federal Register on August 14, 2019. Payment is made under the PFS for services furnished by physicians and other practitioners in all sites of service, including nurse practitioners, physician assistants, physical therapists, etc.

Some of the key provisions in this proposed rule include:

• Medicare Telehealth Services: Proposing to add HCPCS codes GYYY1, GYYY2, and GYYY3 to the list of telehealth services, which describe a bundled episode of care for treatment of opioid use disorders.
• Payment for Evaluation & Management (E/M) Services: Proposing to align the E/M coding changes with changes presented by the CPT Editorial Panel for office/outpatient E/M visits. The CPT coding changes retain 5 levels of coding for established patients, reduce the number of levels to 4 for office/outpatient E/M visits for new patients, and revise the code definitions. The CPT changes also revise the times and medical decision-making process for all of the codes and requires performance of history and exam only as medically appropriate. The CPT code changes also allow clinicians to choose the E/M visit level based on either medical decision making or time.
• Physician Supervision Requirements for Physician Assistants (PAs): CMS is proposing to modify their regulation on physician supervision of PAs to give them greater flexibility to practice more broadly in the current health care system in accordance with state laws and scope of practice.
• Therapy Services: In the CY 2019 PFS final rule, in accordance with amendments to the Medicare law, CMS established modifiers to identify therapy services that are furnished in whole or in part by physical therapy (PT) and occupational therapy (OT) assistants, and set a de minimis 10 percent standard for when these modifiers will apply to specific services. CMS also established that the statutory reduced payment rate for therapy assistant services, effective beginning for services furnished in CY 2022, does not apply to services furnished by critical access hospitals because they are not paid for therapy services at PFS rates. Beginning January 1, 2020, these modifiers are required by statute to be reported on claims. CMS is proposing a policy to implement the modifiers as required by statute, and apply the 10 percent de minimis standard, while imposing the minimum amount of burden for those who bill for therapy services while meeting the requirements of the statute.
• Review and Verification of Medical Record Documentation: CMS has received feedback from clinicians in response to their Patients Over Paperwork initiative request for information (RFI). Stakeholders have shared how undue burden is created when physicians and other practitioners, including those serving as clinical preceptors for students, must re-document notes entered into the medical record by other members of the medical team. To reduce burden, CMS is proposing broad modifications to the documentation policy so that physicians, physician assistants, nurse practitioners, clinical nurse specialists, and certified nurse-midwives could review and verify (sign and date), rather than re-documenting, notes made in the medical record by other physicians, residents, nurses, students, or other members of the medical team.
• Care Management Services: CMS is proposing to increase payment for Transitional Care Management (TCM), a care management service provided to beneficiaries after discharge from an inpatient stay or certain outpatient stays. CMS is also proposing a set of Medicare-developed HCPCS G-codes for certain Chronic Care Management (CCM) services.
• Bundled Payments Under the PFS for Substance Use Disorders: CMS is proposing to create new coding and payment for a bundled episode of care for management and counseling for opioid use disorders (OUD).

Contact RCPA Director of Rehabilitation Services Melissa Dehoff with questions.