The medical world turned its eyes to CMS on July 29th for the release of its proposed changes to Medicare for 2020. While there are quite a few positive proposed changes, the consensus seems to think there are still areas that could use some work. With the document content looming over 1700 pages, we went through and picked out some of the stand-out topics for your review.
New Payment Rates
CMS has announced a $0.05 increase to the 2020 Medicare physician fee schedule. This will increase the conversion factor from $36.04 to $36.09.
Chronic Care Management (CCM)
CMS is making progress in trying to make the induction of CCM programs more enticing to providers and as a result, has attempted to streamline the billing process while making it a little less cumbersome and costly.
As proposed, providers will be able to enroll patients who only have one qualifying high-risk chronic condition into a CCM service, and this program is being dubbed Principle Care Management (PCM) services. Medicare outlines that they recognize that all specialties manage beneficiaries with chronic conditions, and PCM would allow broader access to care management for patients with a single serious high-risk condition.
Medicare also revised its payment model for CCM services and proposed to reimburse at a higher rate when managing patients with multiple chronic conditions. With new codes, providers and clinical staff would be paid more for any additional time spent with CCM patients over the previous 20-minute cap, allowing up to an additional 20 minutes to be billed. Keep an eye out for the new CCM codes:
- GCCC1: Chronic care management services - initial 20 minutes of clinical staff time directed by a physician or other qualified healthcare professional, per calendar month, with the following required elements: multiple (two or more) chronic conditions expected to last at least 12 months, or until the death of the patient; chronic conditions place the patient at significant risk of death, acute exacerbation/decompensation, or functional decline; and comprehensive care plan established, implemented, revised, or monitored.
- GCCC2: Chronic care management services- each additional 20 minutes of clinical staff time directed by a physician or other qualified healthcare professional, per calendar month.
Evaluation and Management Visits (E/M)
CMS has proposed retaining five separate payment rates for E/M visits with established patients and reducing the number of payment levels with new patients to four. Along with this, they are proposing a revision of the code definitions. The motive behind this change is to reduce the burden of practice administration costs and increase provider control over visit level determination.
Additional Telehealth Services Covered by Medicare
It’s been proposed that Medicare will add several new codes to the list of approved telehealth services. These new codes are focused on Opioid Use Disorder Treatment and are as defined below:
- GYYY1: Office-based treatment for opioid use disorder, including development of the treatment plan, care coordination, individual therapy, and group therapy and counseling; at least 70 minutes in the first calendar month.
- GYYY2: Office-based treatment for opioid use disorder, including care coordination, individual therapy, and group therapy and counseling; at least 60 minutes in a subsequent calendar month.
- GYYY3: Office-based treatment for opioid use disorder, including care coordination, individual therapy, and group therapy and counseling; each additional 30 minutes beyond the first 120 minutes
Opioid Use Disorder (OUD) Treatments
We may be seeing some flexibility in the way opioid use disorder treatment is delivered with the ability to perform counseling and therapy services via a telemedicine format. CMS is also making OUD treatment cost-free to the beneficiary for a limited duration and incorporating the allowance of Medication-Assisted Treatment (MAT).
Physician Supervision Requirements for Physician Assistants
If your practice utilizes PA’s, then Medicare is incorporating some greater flexibility regarding their regulations around physician supervision. Of course, individual state law and state scope of practice will still apply and will dictate specific practice scope as applicable.
What Is the Healthcare World Saying About These New Proposed Changes?
Via an article released by MedPage Today, the MGMA is expressing that their providers are a little frustrated with the minimal $0.05 fee schedule increase, and rightfully so with the exponential growth of cost inflation, especially in healthcare. Also noted as a concern in the article, the Medicare Access and CHIP Reauthorization Act of 2015 (MACRA) was supposed to enable providers to increase Medicare payments by as much as 9 percent in 2022, but the new proposed rule changes that and will only create a payment adjustment of 1.4 percent.
Naturally, CMS is putting a positive spin on their proposed changes, but overall it does seem like there is quite a bit of compromise, and it appears that CMS is paying attention to provider input. CMS is putting a good faith effort into helping providers streamline processes and decrease administrative burden with the mutual goal of improving patient-centered care and decreasing the overall cost of delivering healthcare. The new proposed changes will help reduce documentation requirements and streamline reporting requirements, improve the accuracy of CCM payments, and reduce the burden associated with billing CCM services. According to a CMS press release, this new drive towards value-based care is projected to save 2.3 million hours per year in provider and administration time and will push us closer to the Trump Administration vision of a patient-driven healthcare system.
So, how do you feel about the new proposed CMS 2020 changes?