Following the Centers for Medicare and Medicaid Services’ (CMS) release of the CY 2020 Medicare Physician Fee Schedule (PFS) and Quality Payment Program (QPP) proposed rule on July 29, the AUA developed an easy reference on how the proposed rule could affect urology offices.
We have developed impact tables (see below) to identify some of the most common urology procedures in the office and facility setting. The tables display the difference in payment from 2019 to 2020 proposed values in relative value units (RVUs) for physician work, practice expense and malpractice. Please note that these are based on national rates, and they do not reflect the 2 percent payment reduction required by the sequestration, or payment adjustments based on geographical locations. For changes to other urology codes, Addendum B Relative Value Units of the Proposed Rule (included in the CY 2020 PFS Proposed Rule Addenda file; choose Addendum B) will identify the new proposed CY 2020 values for all CPT codes. The AUA continues to identify areas of concern for urology within the proposed rule, including:
- Changes to how evaluation and management (E/M) services will be documented and paid for;
- Valuation of specific urology codes;
- The Quality Payment Program and changes made to the Merit-based Incentive Payment System (MIPS) quality performance scoring methodology;
- Updates and changes made to the Open Payments program;
- Modification of physician supervision requirements for physician assistants (PAs);
- Request for Information (RFI) on solutions to reduce the unnecessary burden created by the physician self-referral law, “Stark Law.”
Specifically, CMS proposes to adopt the following policies for office/outpatient E/M visits effective January 1, 2021:
- Separate payment for the five levels of established office/outpatient E/M visit CPT codes and four levels of new office/outpatient E/M visit CPT codes, as revised by the American Medical Association CPT Editorial Panel effective January 1, 2021 and resurveyed by the AMA RUC, with minor refinement. This would include deletion of CPT code 99201 (Level 1 new patient office/outpatient E/M visit) and adoption of the revised CPT code descriptors for CPT codes 99202-99215;
- Elimination of the use of history and/or physical exam to select among code levels;
- Choice of time or medical decision making to decide the level of office/outpatient E/M visit (using the revised CPT interpretive guidelines for medical decision making);
- Payment for prolonged office/outpatient E/M visits using the revised CPT code for such services, including separate payment for new CPT code 99XXX and deletion of HCPCS code GPRO1 (extended office/outpatient E/M visit) that was previously finalized for 2021;
- Revise the descriptor for HCPCS code GPC1X and delete HCPCS code GCG0X; and
- Increase in value for HCPCS code GCG1X and allowing it to be reported with all office/outpatient E/M visit levels.
The AUA will continue to monitor these changes and report important issues in the near future. View the full 2020 Medicare Physician Fee Schedule and Quality Payment Program proposed rule and related fact sheets on how the proposal impacts the Quality Payment Program and the Physician Fee Schedule. CMS is accepting comments on the proposed rule through September 27, 2019. Any organization, individual physician or citizen can comment. In commenting, please refer to file code CMS-1715-P.
How to Comment
Comments, including mass comment submissions, must be submitted in one of the following three ways (please choose only one of the ways listed):
1. Submit electronic comments on this regulation to http://www.regulations.gov. Follow the "Submit a comment" instructions.
2. Mail written comments to the following address ONLY:
Centers for Medicare & Medicaid Services
Department of Health and Human Services
P.O. Box 8016
Baltimore, MD 21244-8016
Please allow sufficient time for mailed comments to be received before the close of the comment period.
3. By express or overnight mail, send written comments to the following address ONLY: Centers for Medicare & Medicaid Services
Department of Health and Human Services
Mail Stop C4-26-05
7500 Security Boulevard
Baltimore, MD 21244-1850
The charts below show the effect of the 2020 Medicare Physician Fee Schedule on some of the most utilized CPT codes by urologists in the facility and non-facility setting.