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AUA Comments to CMS on 2021 Proposed Medicare Physician Fee Schedule

The Centers for Medicare & Medicaid Services (CMS) released the 2021 Medicare Physician Fee Schedule proposed rule (which also includes updates for the Quality Payment Program and other Medicare Part B payment policies) on August 10, 2020. The AUA submitted comments on the proposed rule on October 5.

Related: View the AUA’s Top Takeaways on the proposed rule for the 2021 Medicare Physician Fee Schedule.

The AUA’s comment letter specifically addresses the valuation of specific codes; refinements to the outpatient evaluation and management services policy; telehealth and other services involving communications-based technology services, and proposed updates to the Quality Payment Program, including the MIPS Value Pathways and Qualified Clinical Data Registries.

The table below outlines key provisions in the MPFS rule and the AUA’s position on each. Additional details are available in the comment letter.

AUA Position
on Proposed Rule
AUA Comments
Conversion Factor CMS proposes a 10.6 percent cut to the conversion factor; the AUA opposes the reduction.
Specialty Impact The proposed rule would result in an 8 percent increase in E/M services for urology. The AUA believes that increases could range from 2 percent to 6 percent depending upon the case mix.
AUA Position
on Proposed Rule
AUA Comments
Implementation of add-on code
The AUA continues to support the implementation of this add-on code to capture additional time spent on the date of service above that for a level 5 visit. The AUA also supports the proposal that CPT 99XXX is only available once a physician has exceeded the maximum, rather than the minimum, time associated with a new or established patient level 5 visit.
Time calculation
The AUA recommends CMS align its reporting rules for 99XXX with CPT’s coding conventions for other time-based services.
HCPCS Code GPC1X The AUA supported this add-on code in last year’s comments, and continues to do so, as well as provides examples of how members may utilize it.
Telehealth and Other Services Involving Communications Technology
AUA Position
on Proposed Rule
AUA Comments
Permanent and Temporary Addition of Services to the Telehealth List The AUA supports and appreciates the agency’s proposal to permanently add GPC1X, 99XXX, 99224, 99335, 99347 and 99348 to the Medicare telehealth services list.
Virtual Check Ins The AUA supports proposal to develop and value a code to describe a longer virtual check-in of 11-20 minutes than the current G20X2, and believe there will be significant need to provide telephonic E/M care to patients after the public health emergency concludes.
Audio-Only Visits The AUA recommends CMS amend its telehealth regulations to allow for audio-only services to continue after the public health emergency concludes, and welcomes the opportunity to work with CMS to explore how to expand patient access to audio-only care while limiting potential fraud and abuse.
Direct Supervision
Teaching Services Supervision The AUA supports the proposal to permit teaching physician presence via audio-visual real-time communication, and proposes permitting teaching presence by telephone only at the discretion of the supervising physician. AUA supports the clinical judgement of the physician to determine which modality should be used.
Staff Supervision The AUA encourages CMS to support policies that permit remote supervision of staff, given its potential to increase access to urological care after the COVID-19 public health emergency concludes.
Incident-to The AUA supports any incident-to service that is billable in person, to be billable with telemedical supervision (audio-visual), at the discretion of the physician.
Valuation of Specific Urology Services
AUA Position
on Proposed Rule
AUA Comments
CPT Code 558XX
Transrectal High Intensity Focused US Prostate Ablation
The AUA urges CMS to accept a work RVU of 19.53, based on a revised crosswalk.
CPT Codes 57282
Colpopexy, vaginal; extra-peritoneal approach (sacrospinous, iliococcygeus)
The AUA believes that CMS’ rationale to recommend a lower work RVU for this code based on the “significant decrease in total time” is flawed and unjustified. The AUA urges CMS to accept a work RVU of 13.48 as recommended by the RUC.
CPT 57283
Colpopexy, vaginal; intra-peritoneal approach (uterosacral, levator myorrhaphy)
The AUA strongly urges CMS to accept a work RVU of 13.51 as recommended by the RUC.
CPT 57425
Laparoscopy Colpopexy
The AUA urges CMS to accept the RUC-recommended work value of 18.02 based on a robust survey and an increase for which compelling evidence was found, rather than setting a value based on the change in time and inappropriate reference codes.

In the proposed rule, CMS asked for answers to a number of questions regarding MIPS Value Pathways (MVPs) to which the AUA provided comments. Additionally, the agency also proposes a number of updates to the Quality Payment Program in 2021, including updating the standards for QCDR measures, including:

  • Modifications to the QCDR measure testing requirement
  • Requiring that QCDR measures must be fully tested at the clinician level in order to be considered for inclusion in an MVP.

The AUA supports CMS’ proposal to allow QCDRs to support MVPs beginning with the 2022 performance period. AUA is concerned, however, by the proposal to require that QCDRs conduct annual data validation audits. While AUA appreciates the need for QCDRs to utilize accurate information, the proposed audit structure will impose significant costs on the small nonprofit entities, such as the AUA, that operate these registries.