Highlight E/M, Opioid Use Treatment, PAs, and Single-Disease Care in 2020 MPFS Final Rule

Medicare Physician Fee Schedule 2020 final rule

Medicare has released the Medicare Physician Fee Schedule (MPFS) for 2020. Let’s see how it stacks up against some of the proposals from Medicare that we looked at back in August.

Expect Separate Payment for E/M Office Levels in 2021

Even though we’re still in 2019, a lot of us have 2021 E/M coding changes on our mind. In the MPFS 2020 final rule, Medicare confirms that they won’t be moving forward with a previous plan to blend payment rates for certain office/outpatient E/M codes (such as getting the same payment whether you report 99202, 99203, or 99204).

As Medicare indicated in the 2020 MPFS proposed rule, you will continue to get distinct rates for each office/outpatient E/M code (99202-99215) you report for 2021 dates of service. Code 99201 is not listed because the plan is for 99201 to be deleted effective Jan. 1, 2021.

To reflect the differences in resource costs between certain types of office/outpatient E/M visits, Medicare proposed to add a code preliminarily identified as GPC1X (Visit complexity inherent to evaluation and management associated with medical care services that serve as the continuing focal point for all needed health care services and/or with medical care services that are part of ongoing care related to a patient’s single, serious, or complex chronic condition. (Add-on code, list separately in addition to office/ outpatient evaluation and management visit, new or established)).

This code has been finalized as a 2021 change, but the final rule states that there could be additional updates, particularly if the CPT® code set revises E/M options in a way that makes GPC1X a duplicate code.

Add These Codes for Opioid Use Treatment

The changes above are for 2021, but in 2020, Medicare coding and coverage for opioid use treatment will have some updates. Medicare-enrolled opioid treatment programs need to quickly get to know new HCPCS Level II codes G2067 to G2080. Those codes will be effective Jan. 1, 2020:

  • Codes G2067-G2073 apply to medication assisted treatment (with the medication listed in the code). Each code is a weekly bundle that includes dispensing, administration, or both; substance use counseling; individual and group therapy; and any toxicology testing performed. The final rule states the counseling and therapy can involve two-way interactive audio-video communication technology if clinically appropriate and compliant with relevant rules.
  • Codes G2074 and G2075 are similar to the codes above but differ slightly. Code G2074 states “not including the drug” and doesn’t reference administration or dispensing. Code G2075 is for treatment with “medication not otherwise specified.”
  • Code G2076 is an add-on code that applies to intake activities, such as physical evaluation, initial assessment, short-term patient goals, and similar items.
  • Code G2077 is another add-on code, this time for periodic assessment to determine appropriate services and treatment for the patient.
  • Codes G2078 (take-home methadone supply) and G2079 (take-home buprenorphine) are add-on codes that cover a supply of up to seven additional days.
  • Code G2018 is an add-on code that covers each additional 30 minutes of counseling in a week.

Opioid treatment programs can get a quick overview of changes for treatment services and payment in the MPFS 2020 fact sheet.

Size Up Language Changes for PA Supervision

To bring requirements for physician supervision of physician assistants (PAs) in line with PAs’ increasing autonomy and evolving state requirements, the 2020 MPFS finalizes a rule that PAs must furnish services according to state law and state scope of practice. If the state laws or rules describe the practice relationship required between physicians and PAs (such as collaborative practice requirements), then Medicare considers that to be describing a form of supervision.

If a state doesn’t have laws or rules about physician supervision of PAs, “physician supervision is a process in which a PA has a working relationship with one or more physicians to supervise the delivery of their health care services. Such physician supervision is evidenced by documenting at the practice level the PA’s scope of practice and the working relationships the PA has with the supervising physician/s when furnishing professional services.”

Update Coding for Disease-Specific Care Management

The 2020 MPFS final rule provides insights into new 2020 HCPCS Level II codes for comprehensive care management of a single high-risk disease:

  • G2064 (Comprehensive care management services for a single high-risk disease, e.g., principal care management, at least 30 minutes of physician  or other qualified health care professional  time per calendar month with the following elements: one complex chronic condition lasting  at least 3 months,  which is the focus of the care plan, the condition is of sufficient severity to place patient at risk of hospitalization or have been the cause of a recent hospitalization, the condition requires development or revision of disease-specific care plan, the condition requires frequent adjustments in the medication regimen, and/or the management of the condition is unusually complex due to comorbidities)
  • G2065 (Comprehensive care management for a single high-risk disease services, e.g. principal care management, at least 30 minutes of clinical staff time directed by a physician or other qualified health care professional, per calendar month with the following elements: one complex chronic condition lasting at least 3 months, which is the focus of the care plan, the condition is of sufficient severity to place patient at risk of hospitalization or have been cause of a recent hospitalization, the condition requires development or revision of disease-specific care plan, the condition requires frequent adjustments in the medication regimen, and/or the management of the condition is unusually complex due to comorbidities)

Don’t miss the requirement in the MPFS that “ongoing communication and care coordination between all practitioners furnishing care to the beneficiary must be documented by the practitioner billing for PCM in the patient’s medical record.” The goal of that requirement is to prevent fractured care for a patient with multiple conditions. You also will need documentation of the patient’s consent to qualify to report these codes.

What About You?

What items from the MPFS do you want to know more about?

 

About 

Deborah works on a wide range of TCI SuperCoder projects, researching and writing about coding, as well as assisting with data updates and tool development for our online coding solutions. Since joining TCI in 2004, she’s covered the ins and outs of coding for radiology, cardiology, oncology and hematology, orthopedics, audiology, and more.

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