Medicare Physician Fee Schedule Proposed Rule Reflects AMA and RUC Input

CMS Accepts AMA Revised E/M Codes and RUC Recommended Values

The Centers for Medicare & Medicaid Services (CMS) has released the Medicare Physician Fee Schedule Proposed Rule for CY 2020. The rule proposes changes to CPT® codes 99201-99215 for office/outpatient evaluation and management (E/M) services, changes to physician supervision requirements for physicians assistants, provides for documentation burden reduction by changing the review and verification process of a medical record by other health care professionals and outlines changes to care management services, including increasing payment for transitional care management services. CMS published a Fact Sheet that outlines these policies along with many other proposed changes.

Most importantly, CMS proposed to accept, effective January 1, 2021, the American Medical Association (AMA) CPT® Editorial Panel approved revisions to the office visit E/M CPT® codes. The revisions to this code set came about after the AMA convened a work group comprised of CPT® Editorial Panel members and members of the Relative Value Scale Update Committee (the RUC). The goal of the E/M work group was to create an alternative solution to CMS’s E/M code collapse proposal that would have resulted in blended payment rates for this set of E/M codes.  

IDSA, along with nearly 50 other medical specialty societies, participated in a RUC survey to value the revised codes. This survey was one of the most robust surveys ever conducted by the RUC. Given that the survey was representative of the physician community, CMS has proposed to adopt the RUC recommended values for the revised E/M codes. The work RVUs for the codes have been increased, which is a welcome sign that CMS is beginning to understand the value of the complex, often time-consuming cognitive care that infectious diseases physicians provide to their patients.

IDSA staff along with members of the Clinical Affairs Committee will be preparing comments for submission to CMS. In the meantime, should you have any questions about the E/M provisions or any other proposals in the rule, please contact Kay Moyer in the Clinical Affairs department of IDSA, kmoyer@idsociety.org.