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Volume 15, Issue 3 Download for iPad

CMS CY 2021 PROPOSED RULES

On August 4, 2020, the Centers for Medicare and Medicaid Services (CMS) released the proposed CY 2021 Medicare Physician Fee Schedule (PFS) and Hospital Outpatient Prospective Payment System (OPPS) rules. You can read these rules, and comments that have been submitted at www.regulations.gov. For the PFS proposed rule at: https://www.regulations.gov/document?D=CMS-2020-0088-1604 and the OPPS proposed rule at: https://www.regulations.gov/document?D=CMS-2020-0090-0003.

PHYSICIAN FEE SCHEDULE PROPOSED RULE (PFS) CALENDAR YEAR (CY) 2021 1

CY 2021 Conversion Factor and Budget Neutrality

The Conversion Factor (CF), is a national dollar multiplier and is used to convert the geographically adjusted Relative Value Units (RVUs) to determine the Medicare-allowed payment amount for a particular physician service. The CF is a complex calculation that is updated annually.  

Without getting into the complex formula, each year the CF is calculated by taking the previous year’s CF adjusting it by the Statutory Update Factor (0.00% in CY 2021) and the RVU Budget Neutrality Adjustment (-10.61% in CY 2021) Figure 1.

If the provisions of the CY 2021 proposed rule are finalized as proposed, the Medicare CF would be reduced from $36.09 in 2020, to $32.26 (a decrease of nearly 11%), effective Jan. 1, 2021.

As required by law, any changes to the RVUs that increase or decrease expenditures for physicians' services overall by more than $20 million must be offset by decreases or increases in payments for other services, a process referred to as "budget neutrality."

The significant budget neutrality adjustment for CY 2021, is largely due to changes to the office and outpatient evaluation and management (E/M) services’ RVUs, and the creation of the add-on code for visit complexity GPC1X (Note: this is a placeholder code until the new code is established).

CY 2021 PFS Conversion Factor
CY 2020 Conversion Factor   36.0896
Statutory Update Factor 0.00 percent (1.0000)  
CY 2021 RVU Budget Neutrality Adjustment -10.61 percent (0.8939)  
CY 2021 Conversion Factor   32.2605

Figure.1.  Calculation of CY 2021 PFS Conversion Factor.  Source: Table 88 Proposed CY 2021 Medicare Physician Fee Schedule Rule

In response to the significant reduction of nearly 11% to the Medicare conversion factor, the American Medical Association (AMA), the American Society of Clinical Oncology (ASCO) and other industry groups are urging Congress to suspend Medicare’s budget neutrality requirement in 2021. 2, 3 Because the budget neutrality requirement is mandated by statute, only Congress can waive it. Suspending the budget neutrality requirement would substantially change the specialty impact and reduce provider burden.

Table 90 of the proposed PFS rule shows the estimated impact on total allowed charges by specialty if the rule is finalized as proposed. Among the specialties, those that are estimated to have the highest decreases in payment include nurse anesthetists and radiology at -11%, chiropractors at -10%, and cardiac surgery, interventional radiology and pathology at -9%. Those with the highest estimated payment increases include endocrinology at +17%, rheumatology at +16%, hematology/oncology at +14%, and family practice at +13%.

The specialty impact varies widely, and this is largely due to the proposed payment rate increases for office/outpatient evaluation and management codes, the new visit complexity code (GPC1X), and the budget neutrality adjustment triggered by the increases.  In comparison, in the CY 2020 PFS impact by specialty ranged from -4% to +3% .

Impact of Proposed Changes by Selected Specialties

Specialty Allowed Charges in millions Impact of Work RVU Changes Impact of Work RVU Changes Impact of Work RVU Changes Combined Impact
Hematology/Oncology $1,702 9% 5% 1% 14%
Nurse Practitioner $5,069 5% 3% 0% 8%
Physician Assistant $2,888 5% 3% 0% 8%
Radiation Oncology and Radiation Therapy Centers $1,803 -3% -3% 0% -6%
Rheumatology $546 10% 6% 1% 16%

Source: Table 90, CY 2021 Proposed Physician Fee Schedule

Office and Outpatient Evaluation and Management Services

Arguably, the most consequential of the proposed policies for CY 2021 PFS are those related to E/M services.

The PFS proposed 2021 rule includes payment rate increases for all but the lowest level of the office/outpatient E/M codes for established patients (Figure 2), along with simplified billing and coding requirements for these services (finalized in the CY 2020 PFS Final Rule, with implementation delayed until 2021). Additionally, CMS will not implement a blended rate for level 2-4 evaluation and management (E/M) visits, and instead will continue to pay for each level of visit.

The payment rate increases and billing and coding changes incorporate revisions recommended by the AMA and generally adopt the new coding, prefatory language, and interpretive guidance framework that has been issued by the AMA’s CPT Editorial Panel regarding the revisions to office/outpatient E/M visit code set (CPT codes 99201 through 99215), which will be effective January 1, 2021.

CMS states that under this new CPT coding framework, history and exam will no longer be used to select the level of code for office/outpatient E/M visits. Instead, an office/outpatient E/M visit will include a medically appropriate history and exam, when performed, and be based on either the level of medical decision making (MDM) or the total time personally spent by the reporting practitioner on the day of the visit (including face-to-face and non-face-to-face time).

The changes also include deletion of CPT code 99201 (Level 1 office/outpatient visit, new patient), as finalized in the CY 2020 PFS. The CPT Editorial Panel decided to eliminate CPT code 99201 because CPT codes 99201 and 99202 are both straightforward medical decision making (MDM) and are largely differentiated by history and exam elements which would no longer be used to select the level of code for office/outpatient E/M visits.

CMS’ alignment with the E/M billing and coding structure developed by the AMA CPT Editorial Panel and RVS Update Committee (RUC) is important so providers are not having to deal with two separate sets of E/M billing and coding structures (one for Medicare and one for private payers). Still, providers are urged to reach out to their private payers to verify that the payers will be following the AMA CPT guidelines for these services.

The simplified billing and coding requirements should be a welcome change that decreases providers’ administrative burden.

As mentioned earlier, the increased payments for E/M services (along with other proposed increases) would exceed $20 million. As a result, under the statutorily mandated budget neutrality this would be offset by decreases in payments for other services through a decrease in the conversion factor. So, while some providers would see substantial increases in payments others would see corresponding decreases. In general, providers that bill more high-level established patient visits would see the largest increases, while providers that bill fewer E/M visits would experience the greatest decreases.

Proposed Payment Changes

CPT Code Description 2020 Non-facility 2020 Facility Proposed CY 2021 Non-facility Proposed CY 2021 Facility % Change Non-facility % Change Facility
99202 Office/outpatient visit new $77.23 $51.61 $69.04 $46.13 -10.60% -10.62%
99203 Office/outpatient visit new $109.35 $77.23 $106.14 $78.07 -2.94% 1.09%
99204 Office/outpatient visit new $167.09 $132.09 $159.37 $127.75 -4.62% -3.29%
99205 Office/outpatient visit new $211.12 $172.51 $210.66 $173.88 -0.22% 0.79%
99211 Office/outpatient visit established $23.46 $9.38 $22.26 $8.71 -5.12% -7.14%
99212 Office/outpatient visit established $46.19 $26.35 $54.20 $34.20 17.34% 29.79%
99213 Office/outpatient visit established $76.15 $52.33 $86.78 $63.23 13.96% 20.83%
99214 Office/outpatient visit established $110.43 $80.48 $122.91 $93.23 11.30% 15.84%
99215 Office/outpatient visit established $148.33 $113.68 $172.27 $137.75 16.14% 21.17%
99495 Trans care mgmt. (TCM) within 14 days of discharge $187.67 $125.59 $197.43 $135.82 5.20% 8.15%
99496 Trans care mgmt. (TCM) within 7 days of discharge $247.94 $165.65 $267.12 $184.85 7.74% 11.59%

Figure 2. Proposed Payment Changes Source: Addendum B Relative Value Units and Related Information CY 2021 CMS 1734-P

In the CY 2020 PFS proposed rule, CMS sought comment on the times associated with the office/outpatient E/M visits as recommended by the AMA RVS Update Committee (RUC).   The approach used by the AMA RUC to develop recommendations sometimes resulted in two conflicting sets of times: the component times as surveyed and the total time as surveyed. Citing the lack of clarity about why the sum of minutes in the components would differ from the total minutes, CMS is proposing to adopt the actual total times (rather than the RUC recommended total times for CPT codes 99202 though 99215). Figure 3.

RUC Recommended Pre -, Intra, Post-Service Times,
RUC Recommended Total Times for CPT Codes 99202-99215 and Actual Total Time

HCPCS

Pre-Service Time

Intra-Service Time

Immediate Post-Service Time

Actual Total Time

RUC Recommended Total Time

99202 2 15 3 20 22
99203 5 25 5 35 40
99204 10 40 10 60 60
99205 14 59 15 88 85
99211   5 2 7 7
99212 2 11 3 16 18
99213 5 20 5 30 30
99214 7 30 10 47 49
99215 10 45 15 70 70

Figure 3. Table 17: RUC-Recommended Pre-, Intra-, Post-Service Times, RUC-Recommended Total Times for CPT codes 99202-99215 and Actual Total Time. Source: CMS CY 2021 Proposed PFS Rule.

Payment for Visit Complexity

In the CY 2020 final rule, CMS finalized separate payment for HCPCS add-on code GPC1X (GPC1X is a placeholder code, the permanent code will be assigned in the future), to provide payment for visit complexity inherent to certain office/outpatient E/M services.  HCPCS code GPC1X has an estimated Medicare national payment rate of $10.65.

Questions remain as to when exactly the service described by the placeholder code GPC1X should be billed, how often it can be billed, by whom, and what documentation will be required.

In response to CMS’ request for comments on code GPC1X, the AMA RUC responded that they are unable to provide a recommendation on code GPC1X citing “the lack of clarity on the purpose, use of and reporting of the code." The RUC also expressed concern that CMS’ assumption that certain specialties (family medicine, general practice, internal medicine, pediatrics, geriatrics, nurse practitioner, physician assistant, endocrinology, rheumatology, hematology/oncology, urology, neurology, obstetrics/gynecology, allergy/immunology, otolaryngology, interventional pain management, cardiology, nephrology, infectious disease, psychiatry, and pulmonary disease) would report code GPC1X with 100% of their new or established patient E/M office visits, resulting in an approximate $2.6 billion increase in spending and a 3% decrease to the CY 2021 Medicare conversion factor. 4

Prolonged Services

CMS proposed several changes to CPT 99XXX (Prolonged office or other outpatient evaluation and management service(s) (beyond the total time of the primary procedure which has been selected using total time), requiring total time with or without direct patient contact beyond the usual service, on the date of the primary service; each additional 15 minutes (List separately in addition to CPT codes 99205, 99215 for office or other outpatient evaluation and management services)). CPT 99XXX is a placeholder code. CPT 99XXX has an estimated Medicare national payment rate of $19.68.

CMS changed the prolonged services billing time when billed with the level 5 office/outpatient visit level so that CPT code 99XXX could be reported when the maximum time for the level 5 office/outpatient E/M visit is exceeded by at least 15 minutes on the date of service. CPT 99XXX is only reported when time is used to select the visit level, and only time of the physician or qualified healthcare professional is counted. CMS provides examples of reporting 99XXX in Tables 22 and 23 of the proposed rule.

Table 22: Proposed Prolonged Office/Outpatient E/M Visit Reporting – New Patient

CPT Code(s) Total Time Required for Reporting
99205 60-74 minutes
99205 x 1 and 99XXX x 1 89-103 minutes
99205 x 1 and 99XXX x 2 104-118 minutes
99205 x 1 and 99XXX x 3 or more for each additional 15 minutes 119 or more

*Total time is the sum of all time, including prolonged time, spent by the reporting practitioner on the date of the visit.

Table 23: Proposed Prolonged Office/Outpatient E/M Visit Reporting – Established Patient

CPT Code(s) Total Time Required for Reporting
99215 40-54 minutes
99215 x 1 and 99XXX x 1 69-83 minutes
99215 x 1 and 99XXX x 2 84-98 minutes
99215 x 1 and 99XXX x 3 or more for each additional 15 minutes 99 or more

*Total time is the sum of all time, including prolonged time, spent by the reporting practitioner on the date of the visit.
Source: CMS CY 2021 Proposed PFS Rule.

Telehealth Services

The proposed rule also expands and extends certain telehealth services including home visits for the evaluation and management of a patient (in the case where the law allows telehealth services in the patient’s home). However, CMS states that while they are not proposing to continue payment for audio-only E/M visits once the public health emergency (PHE) ends, they are seeking input on audio only visits.  CMS also proposes adding additional services to the Medicare telehealth list on a Category 1 basis including Prolonged Services (99XXX) and Visit Complexity Associated with Certain Office/Outpatient E/Ms (GPC1X).

In comments to CMS on the CY 2021 proposed rule, ASCO urges CMS to permanently cover and reimburse audio-only telehealth services citing the need for flexibility in order to help keep cancer patients, who are often immuno-compromised, at home and away from unnecessary exposure to all illnesses not just COVID-19.

CMS also clarified in the rule that telehealth does not apply when the provider and the patient are in the same location, even if technology is used in the exchange.

Scope of Practice and Supervision Requirements

The rule addresses professional scope of practice and related issues. Scope of practice proposed changes and clarifications include:

  • To amend the basic rule under the regulation at § 410.32(b)(1) to allow NPs, CNSs, PAs or CNMs to supervise diagnostic tests on a permanent basis as allowed by state law and scope of practice.
  • Pharmacists may provide services incident to the services, and under the appropriate level of supervision, of the billing physician or NPP, if payment for the services is not made under the Medicare Part D benefit.  This includes providing the services incident to the services of the billing physician or NPP and in accordance with the pharmacist’s state scope of practice and applicable state law. 
    • Specifically, CMS clarifies that pharmacists that provide medication management services that are billed to Medicare Part B may be considered auxiliary personnel and provide the medication management services incident to the billing physician or non-physician practitioner (NPP).  CMS, states that this clarification may encourage pharmacists to work with physicians and NPPs in new ways where pharmacists are working at the top of their training, licensure and scope of practice.

Removal of National Coverage Determinations

CMS solicited stakeholder feedback on the removal of nine outdated or obsolete National Coverage Determinations (NCDs). Table 37 of the proposed rule identifies the NCDs proposed for removal:

  • Extracorporeal Immunoadsorption (ECI) using Protein A Columns
  • Electrosleep Therapy
  • Implantation of Gastroesophageal Reflux Device
  • Apheresis (Therapeutic Pheresis)
  • Abarelix for the Treatment of Prostate Cancer
  • Histocompatibility Testing
  • Cytogenetic Studies
  • Magnetic Resonance Spectroscopy

CMS is also requesting comments and suggestions on other NCDs to remove. When NCDs are removed, Medicare Administrative Contractors (MACs) are no longer required to follow those coverage policies when covering services for beneficiaries. The MACs would then have flexibility to determine coverage for beneficiaries in their geographic areas based on more recent evidence and information.

ASCO addressed the removal of NCDs in their comments to CMS on the proposed rule expressing their concern that the action may set a precedent to facilitate removal of relevant and more widely used NCDs, which may reduce patient access to care.5

Medical Record Documentation

In the proposed rule, CMS clarifies that physicians and NPPs, including therapists, may review and verify (sign and date) documentation entered into the medical record by members of the medical team for their own services that are paid under the PFS.

Quality Payment Program

Merit-Based Incentive Payment System

CMS previously determined that Merit-Based Incentive Payment System (MIPS) Value Pathways (MVPs) would begin with the 2021 performance period. However, due to stakeholder concerns about this timeline and with the additional burdens posed by the COVID-19 PHE, CMS will not introduce any MVPs into the program for the 2021 performance period.

Additionally, CMS states they have limited policy proposals to focus on the highest priorities of the program.

CMS proposes a new APM (Alternative Payment Model) Performance Pathway (APP) reporting option in 2021 to align with the MVP framework. CMS says the new APM APP will reduce reporting burden and enhance alignment across APMs. Accountable Care Organizations (ACOs) would report one set of quality measures that would satisfy Medicare Shared Savings Program (MSSP) and MIPS requirements. CMS will sunset the CMS Web Interface as a collection type beginning in the 2021 performance period.

Participation Options

CMS will continue to allow MIPS eligible clinicians (ECs) to participate in MIPS as individuals or as part of a group or virtual group and they are expanding the use of the APM Entity submitter type to allow the use of all MIPS submission mechanisms.

Performance Threshold and Performance Category Weights

CMS proposes the following performance threshold and category weights for the 2021 performance period:

  • Performance threshold to be 50 points – CMS had previously finalized a performance threshold of 60 points for 2021, CMS is asking for comments on the proposed lower performance threshold of 50 points
  • Quality performance category to be weighted at 40% (5% decrease from 2020)
  • Cost performance category to be weighted at 20% (5% increase from 2020)
  • Promoting Interoperability performance category to be weighted at 25% (no change from 2020)
  • Improvement Activities performance category to be weighted at 15% (no change from 2020)

The time frame for reporting is a full year for the Quality and Cost components; and, 90 days for Promoting Interoperability and Improvement Activities.

Performance Category Proposals

Quality Performance Category: CMS proposes using performance period benchmarks to score quality measures for the 2021 performance period. CMS is concerned that the agency may not have a representative sample of historic data for 2019 because of the COVID-19 public health emergency, which impacted data submission in 2020 and which could skew benchmarking results.

Cost Performance Category: CMS proposes updating existing measure specifications to include telehealth services that are directly applicable to existing episode-based cost measures and the Total Per Capita Cost (TPCC) measure.

Improvement Activities Performance Category: CMS proposes making minimal updates to the Improvement Activities Inventory. CMS will establish policies in relation to the Annual Call for Activities including an exception to the nomination period timeframe during the PHE. CMS also proposes establishing a process for agency-nominated improvement activities.

Promoting Interoperability Performance Category: CMS proposes retaining the Query of Prescription Drug Monitoring Program (PDMP) measure as an optional measure and to propose to make it worth 10 bonus points.

Scoring Proposals (COVID-19 Flexibilities for performance year 2020)

CMS is proposing to change the maximum number of points available for the complex patient bonus from 5 points to 10 points to account for the additional complexity of treating patients during the COVID-19 Public Health Emergency. CMS is proposing this increase for the 2020 performance period only.

Beginning with the 2020 performance period, CMS proposes allowing APM Entities to submit an application to reweight MIPS performance categories as a result of extreme and uncontrollable circumstances.

Advanced Alternative Payment Models

For the 2021 participation year, Medicare patients who are prospectively attributed to an APM entity would not be included in the denominator for the APM threshold calculation.

CMS is also proposing to establish a targeted review process through which an APM entity or eligible clinician may request review of a Qualified APM Participant (QP) or partial QP determination if they believe, in good faith, that an eligible clinician was omitted from a Participation List because of a CMS clerical error. 

For performance year 2020, all ACOs are considered affected by the Public Health Emergency (PHE) for the COVID-19 pandemic, and the Shared Savings Program extreme and uncontrollable circumstances policy applies. Additionally, for performance year 2020 only, CMS is proposing to waive the requirement for ACOs to field a Consumer Assessment of Healthcare Providers and Systems (CAHPS) for ACOs survey. Consequently, ACOs would receive automatic full credit for the patient experience of care measures.

Delay in Release of CY 2021 Final Rule
Typically, CMS releases the final rule around Nov. 1, giving providers 60 days to review and prepare for any changes before they take effect on Jan. 1. However, in the proposed rule, CMS states they are waiving the 60-day delay in the effective date and replacing it with a 30-day notification requirement, so the final payment schedule is not expected to be released until Dec. 1, 2020.

HOSPITAL OUTPATIENT PROSPECTIVE PAYMENT SYSTEM (OPPS) PROPOSED RULE 6

OPPS Annual Payment Update
CMS proposed increasing OPPS rates by 2.6% in 2021, based on the projected hospital market basket increase of 3.0% minus a 0.4% adjustment for multi-factor productivity (MFP), with estimated total payments to OPPS providers of $83.9 billion in 2021, up $7.5 billion from 2020. 

340B Drugs

CMS is proposing to further reduce the payment rate for 340B drugs. Under the proposed rule, CMS would pay hospitals ASP minus 34.7% with a 6% add-on payment for overhead and handling, for a net rate of ASP minus 28.7% for separately payable drugs or biologicals acquired through the 340B Program. CMS is also soliciting comments on whether they should instead continue its current policy of paying ASP minus 22.5% for these drugs.

With either policy, rural sole community hospitals, children’s hospitals, and PPS-exempt cancer hospitals would be excepted. These excepted hospitals would continue to report the informational modifier “TB” for 340B acquired drugs and would continue to receive ASP plus 6% for 340B drugs.

Drug Packaging Threshold 

The packaging threshold for drugs without pass-through status is not proposed to increase, for CY 2021 the OPPS packaging threshold is proposed to be $130. Drugs without pass-through status that cost more than $130 per encounter will be paid separately.

Site Neutrality

The July 17, 2020 U.S. Court of Appeals for the District of Columbia Circuit ruled in favor of CMS, stating that their site neutrality regulation was a reasonable interpretation of the statutory authority to adopt a method to control for unnecessary increases in the volume of the relevant service. In light of this, CMS will continue the site-neutral policy in 2021. CMS did not say whether or how they would address reprocessing 2019 claims that were paid at the higher OPPS rate.

Level of Supervision
CMS proposes to make permanent the policy they adopted to reduce, on an interim basis for the duration of the PHE, the minimum default level of supervision for non-surgical extended duration therapeutic services (NSEDTS) to general supervision for the entire service, including the initiation portion of the service. CMS states that changing the level of supervision for NSEDTS permanently would be beneficial to patients and outpatient providers. If finalized, the proposal would apply to NSEDTS furnished on or after January 1, 2021.

Clinical Laboratory Date of Service Policy

CMS is proposing to exclude cancer-related protein-based Multianalyte Assays with Algorithmic Analysis (MAAAs) from the OPPS packaging policy and to add them to the laboratory date of service (DOS) exception. Under this proposal, cancer-related protein-based MAAA tests (CPT codes 81500, 81503,81535, 81536 and 81539) would be billed by the performing laboratory directly to Medicare and that laboratory would be paid directly by Medicare under the Clinical Laboratory Fee Schedule (CLFS).

CY 2021 Medicare Proposed Rules - Resources:

CMS Physician Fee Schedule Proposed Rule: Understanding 4 Key Topics Listening Session: https://www.cms.gov/outreach-and-educationoutreachnpcnational-provider-calls-and-events/2020-08-13

Fact sheet on the CY 2021 Physician Fee Schedule Proposed and Quality Payment Program Proposed Rule: 
https://www.cms.gov/newsroom/fact-sheets/proposed-policy-payment-and-quality-provisions-changes-medicare-physician-fee-schedule-calendar-year-4

CMS Press Release on Expansion of Telehealth Benefits
https://www.cms.gov/newsroom/press-releases/trump-administration-proposes-expand-telehealth-benefits-permanently-medicare-beneficiaries-beyond

2021 Quality Payment Program Proposed Rule & Fact Sheet
https://qpp.cms.gov/mips/mips-value-pathways

Federal Register -  CY 2021 Medicare Physician Fee Schedule Proposed Rule: https://www.federalregister.gov/documents/2020/08/17/2020-17127/medicare-program-cy-2021-revisions-to-payment-policies-under-the-physician-fee-schedule-and-other

CMS CY 2021 Medicare Physician Fee Schedule Proposed Rule Files:
https://www.cms.gov/medicaremedicare-fee-service-paymentphysicianfeeschedpfs-federal-regulation-notices/cms-1734-p

Access the 2021 Medicare Hospital Outpatient Prospective Payment System (OPPS) Proposed Rule at:
https://s3.amazonaws.com/public-inspection.federalregister.gov/2020-17086.pdf?utm_campaign=pi%20subscription%20mailing%20list&utm_source=federalregister.gov&utm_medium=email

Fact Sheet on the CY 2021 Medicare Hospital Outpatient Prospective Payment System and Ambulatory Surgical Center Payment System Proposed Rule:
https://www.cms.gov/newsroom/fact-sheets/cy-2021-medicare-hospital-outpatient-prospective-payment-system-and-ambulatory-surgical-center

1 CMS.gov. Proposed Rule Medicare Program; CY 2021 Payment Policies Under the Physician Fee Schedule and Other Changes to Part B Payment Policies; Medicare Shared Savings Program Requirements; Medicaid Promoting Interoperability Program Requirements for Eligible Professionals; Quality Payment Program; Coverage of Opioid Use Disorder Services Furnished by Opioid Treatment Programs; Medicare Enrollment of Opioid Treatment Programs; Electronic Prescribing for Controlled Substances for a Covered Part D Drug Under a Prescription Drug Plan or an MA–PD Plan; Payment for Office/Outpatient Evaluation and Management Services; Hospital IQR Program; Establish New Code Categories; and Medicare Diabetes Prevention Program (MDPP) Expanded Model Emergency Policy. https://www.govinfo.gov/content/pkg/FR-2020-08-17/pdf/2020-17127.pdf. Accessed August 25, 2020.
2 AMA Press Releases. Medicare Moving Forward with Planned E/M Office Visit Changes. https://www.ama-assn.org/press-center/press-releases/medicare-moving-forward-planned-em-office-visit-changes. Accessed September 1, 2020.
3 ASCO.org. ASCO in Action. Medicare Provider and Hospital Outpatient Reimbursement Proposals Set Stage for 2021 and Post-Pandemic Landscape; Accompanying Executive Order Focused on Telehealth, Rural Care.
 https://www.asco.org/practice-policy/policy-issues-statements/asco-in-action/medicare-provider-and-hospital-outpatient. Accessed September 1, 2020.
4 Regulations.gov. Comment on CMS-2020-0088-1604. 2021 Proposed Rule RUC Comment Letter w Attachments.  https://www.regulations.gov/document?D=CMS-2020-0088-11011. Accessed September 24, 2020.
5 Regulations.gov. ASCO PFS-QPP 2021 Comment Letter. https://www.regulations.gov/document?D=CMS-2020-0088-10979. Accessed September.
6 CMS.gov. CMS-1736-P. Hospital Outpatient Prospective Payment- Notice of Proposed Rulemaking (NPRM). https://www.cms.gov/medicaremedicare-fee-service-paymenthospitaloutpatientppshospital-outpatient-regulations-and-notices/cms-1736-p. Accessed September 1, 2020.


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ABOUT THE EDITOR
Risė Marie Cleland is the Founder and CEO of Oplinc, Inc., a national organization of oncology professionals. Through Oplinc, Inc., Ms. Cleland publishes the weekly Oplinc Fast Facts focusing on the timely dissemination of information pertaining to billing, reimbursement and practice management in the oncology office and Oplinc’s Best Practices Review, which provides a more in-depth look at the issues and challenges facing oncology practices. Ms. Cleland also works as a consultant and advisor for physician practices, pharmaceutical companies and distributors.

IMPORTANT NOTICES
Please note that this newsletter is presented for informational purposes only. It is not intended to provide coding, billing or legal advice. Regulations and policies concerning Medicare reimbursement are a rapidly changing area of the law. While we have made every effort to be current as of the issue date, the information may not be as current or comprehensive when you review it. Please consult with your legal counsel for any specific reimbursement information. For Medicare regulations visit: www.cms.gov.

CPT® is a Trademark of the American Medical Association Current Procedural Terminology (CPT) is copyright 2020 American Medical Association. All Rights Reserved. No fee schedules, basic units, relative values, or related listings are included in CPT. The AMA assumes no liability for the data contained herein.

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