At A Glance: Proposed 2020 Rules for Medicare Fee Schedule, QPP and OPPS

By Policy and Advocacy Brief posted 07-30-2019 15:19


On July 29, the Centers for Medicare & Medicaid Services (CMS) released the proposed rules for the 2020 Medicare Physician Fee Schedule (which includes updates to the Quality Payment Program, Open Payments program and other Medicare Part B policies) and the Outpatient Prospective Payment System (OPPS)/Ambulatory Surgery Center (ASC) Payment System. The AUA actively is reviewing both rules, but there are a few important proposed changes in the proposed fee schedule of which urologists should be aware. More detailed analysis of these changes – and more details on how the proposed rules will affect urology – is forthcoming.

2020 Proposed Conversion Factor

2019 Conversion Factor: $36.04
2020 Proposed Conversion Factor: $36.09

Increase in Allowed Charges for Urology

CMS estimates that the proposed Fee Schedule changes will results in an increase of 1 percent in allowed charges for urology (overall 0 percent increase in work RVUs and 1 percent increase in practice expense RVUs). (Note: This increase is in overall charges; changes for individual codes may vary.) CMS states, "The payment impact for an individual practitioner could vary from the average and would depend on the mix of services he or she furnishes."

Evaluation and Management Coding Updates

CMS proposes to align changes to evaluation and management (E/M) coding with the American Medical Association (AMA) CPT Editorial Panel’s recommendations. This plan maintains five levels of coding for established patients, and decreases the number of code levels to four for new patients. CMS also proposes to adopt the AMA Relative Value Scale Update Committee (RUC) recommended E/M code values, which would result in increases in payment for these codes. Physicians can choose the level of reporting based on medical decision making or time. The E/M changes would go into effect in 2021.

Increase in Allowable E/M Payment for Urology

CMS estimates that the proposed Fee Schedule changes for E/M will result in an increase of 8 percent in allowable charges for urology (overall 4 percent increase in work RVUs and 4 percent increase in practice expense RVUs). 

 Changes in Physician Supervision Requirements for Physician Assistants

Nonphysician practitioners, such as physician assistants (PAs), are among the clinicians covered by the Medicare Physician Fee Schedule. In the proposed 2020 rule, CMS outlines modifications to physician supervision for Physician Assistant (PA) services  in order to give PAs “greater flexibility to practice more broadly in the current health care system in accordance with state law and state scope of practice.”

Quality Payment Program: Merit-based Incentive Payment System (MIPS) Changes

CMS is proposing the following changes in weights for MIPS categories:

MIPS Performance Thresholds: To avoid penalties, MIPS-eligible clinicians must achieve a certain MIPS Final Score based on performance across all categories. MIPS-eligible clinicians who exceed the performance threshold of 45 points (up from 30 in 2019) are eligible to receive upward payment adjustments. Those who exceed the exceptional performance threshold of 80 points (no change from 2019) may qualify for an additional payment adjustment.

Open Payments Program: Updates and Changes

CMS is proposing to expand the definition of “covered recipients” in the Open Payments program to include physician assistants, nurse practitioners, clinical nurse specialists, nurse anesthetists and certified nurse midwives. Additionally, the agency proposes modified payment categories and standardizing data on reported medical devices.

For more information about the proposed 2020 rules, please contact the AUA at