The 2020 physician fee schedule is under regulatory review, but that doesn't mean you can't gain a glimpse of the public comments about the pending E/M changes that CMS will be taking into consideration.
While CMS based its 2021 E/M values on the suggestion of the AMA's own RVS Update Committee (RUC), the AMA calls for a significant increase in payments for services across the board.
"This is a significant reduction to absorb into practices that are already practicing at maximum efficiency. We urge the agency to finalize [its] acceptance of the CPT codes, CPT guidelines and RUC recommendations exactly as implemented by the CPT Editorial Panel and submitted by the RUC. CMS should work with the medical community to urge Congress to implement positive updates to the Medicare conversion factor to offset the deserved increases to office visits," states the AMA's public comments.
The Medical Group Management Association (MGMA), meanwhile, supports both the new direction in payment and the proposal to base code selection on medical decision-making (MDM) or time. But MGMA seeks further clarification from the federal agency on documentation guidance going forward. "MGMA members are concerned that the lack of documentation guidance will result in increased audits and denial of payment," the association's letter to CMS states.
Some groups, including the American Academy of Family Physicians (AAFP), support the revised E/M pay rates but want to see them on the fast track. "Since most family medicine practices already operate on extremely thin margins and these services have been undervalued for decades, we implore CMS to implement these changes in 2020 rather than 2021 as proposed," AAFP states in its public comments letter.
Still others are calling for additional clarity regarding the proposed pay rate changes. "It is entirely possible that our members will not have an accurate estimate of the impact of this proposed rule until November 2020," states AMGA. "This provides them with less than two months before the changes are implemented, which will make internal budgeting and compensation decisions more difficult. CMS should provide additional guidance on this issue as soon as possible to help group practices and integrated delivery systems conduct their internal planning and budgeting."