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E/M-driven redistribution draws scrutiny at AMA Symposium

CHICAGO, Nov. 20 - After several sessions covering the historic E/M code changes moving closer to reality, some audience members here at the CPT and RBRVS 2020 Annual Symposium had pointed questions for CMS officials about the billions of dollars potentially on the move under the physician fee schedule in 2021. 
 
In an expansive conference room filled with hundreds of medical practice professionals, clinicians and other health care stakeholders, the topic of E/M office visits drew lengthy attention and sparked multiple give-and-takes about the payment outlook between federal officials, AMA leaders and audience members.
 
Central to the E/M conversation was the potential impact of a massive redistribution of physician fee schedule funds in 2021 following pay increases to codes 99202-99215.
 
“Medicare payments for office visits will increase, on average, by 13%,” says Peter Smith, M.D., chair of the AMA’s relative value scale update committee (RUC).
 
Because the nine office visit codes gaining a large pay raise comprise roughly 20% of Part B payments, the effect on other services could be drastic because CMS operates the fee schedule in a budget-neutral manner.
 
All told, about $8 billion are expected to be in flux in 2021.
 
“There are many, many reverberations of this major change and the reverberations won’t end anytime soon,” Smith says.
 
But the payment swings may be felt immediately. Some E/M rates are increasing 25% or more, such as the most-billed office visit code, 99214. CMS projections say payments for 99214 will move from $109 per service in 2020 to $136 in 2021, according to Kathy Bryant, senior technical advisor of the hospital and ambulatory policy group with CMS.
 
Immediately following Bryant’s session, multiple audience members asked about the direction of E/M services in 2021, with one person issuing concern about the “devalued RVUs for other specialties.”
 
There’s no “specific process outlined yet,” Bryant responded, adding that CMS officials will be reviewing the question of redistribution in advance of the proposed 2021 Medicare physician fee schedule, expected to be published in the summer of 2020. But Bryant cautions that many factors, including specific payments, could change.
 
“It’s important to remember that we are only estimating these [E/M payment rates],” Bryant says.
 
Meanwhile, AMA officials urged audience members to draw a distinction between the favorable E/M changes on the one side and the challenge of budget neutrality requirements on the other. Yet changes to budget neutrality would require an intervention, either legislative or from a higher order.
 
In other words, budget neutrality is an immutable factor “absent an angel or congressional action,” Smith says.
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