2020 Medicare Physician Fee Schedule Final Rule Released; Includes 2020 QPP Changes

On November 1st, CMS released the CY 2020 MPFS Final Rule.

CMS also released a fact sheet

and press release

on this proposed rule.

2020 MPFS Conversion Factor
The CY 2020 MPFS conversion factor is $36.0896, which reflects the 0.14% budget neutrality adjustment and the 0.00% update adjustment factor as established in MACRA. This is a slight increase from the 2019 conversion factor of $36.0391.

Despite intense advocacy from ASCRS, the AMA, and the surgical community that included a direct meeting with CMS and bipartisan letters from Congress, CMS will not adopt changes to the 10- and 90-day global surgery codes as they continue to evaluate the data.

ASCRS and the surgical community opposed CMS’ policy because it disrupts the relativity of the physician fee schedule by changing the value of some E/M services, but not all, and violates current law that requires Medicare to reimburse physicians equally for the same services regardless of specialty. In addition, CMS’ rationale for not increasing the values because of its ongoing data collection on post-operative care in the global codes runs afoul of the MACRA statute that gave it the authority to study the codes but noted that CMS should continue to update individual code values. We maintain that if CMS identifies specific codes it believes are overvalued, it should refer them to the RUC for review as part of the misvalued code initiative. In addition, we reminded CMS that these values have been increased each time E/M services were revalued since the advent of the physician fee schedule and the Relative-Based Relative Value Scale (RBRVS) in 1992.

Because this policy would violate current law and affects the relativity of the physician fee schedule, we will be working with the surgical coalition to determine our options to prevent CMS from implementing this policy. We will keep members updated as this process moves forward. 

CMS continues modifications to the Quality Payment Program (QPP), which includes the Merit-Based Incentive Payment System (MIPS) program.

Key changes for CY 2020 MIPS performance, which impacts 2022 payment:

  • Increasing the MIPS performance threshold from 30 points in 2019 to 45 points in 2020. 
     
  • Increasing the exceptional performance threshold from 75 points in 2019 to 85 points in 2020.
     
  • Following ASCRS and medical community advocacy, CMS is maintaining the 2019 category weights in 2020 for Quality (45%) and Cost (15%). Promoting Interoperability remains at 25% and Improvement Activities at 15%.
     
  • As a result of ASCRS advocacy, ophthalmology and optometry are removed from attribution of the Total Per Capita Cost Measure (TPCC).
     
  • Increasing the data completeness threshold for the quality data from 60% to 70% of Part B patients submitted via claims, and 60% of all patients to 70% of all patients using all other submission mechanisms.

Payment Adjustments for 2022

Following the MACRA statute, the maximum penalty or bonus for MIPS reporting in 2020 is increasing to 9%, up from 7% in 2021, based on 2019 reporting.

MIPS Value Pathways (MVPs)

In the final rule, CMS indicates that it plans to go forward with its proposal to implement MVPs in performance year 2021. MVPs would be a defined set of measures and activities, including problematic population-health measures, centered on a condition or procedure. Following comments from ASCRS and the medical community that opposed the mandatory nature of the MVPs, CMS noted that it had not determined whether it would make MVPs mandatory in 2021 and will continue to work with stakeholders to take an incremental approach to determining its policies for 2021. 

Removal of Quality Measures

Despite ASCRS and ophthalmic community advocacy, CMS will eliminate the following quality measures:

  • Measure 192, Cataracts: Complications within 30 Days Following Cataract Surgery Requiring Additional Surgical Procedures.
  • Measure 388, Cataract Surgery with Intra-Operative Complications (Unplanned Rupture of Posterior Capsule Requiring Unplanned Vitrectomy

Additional information will be detailed in upcoming editions of Washington Watch Weekly. For questions, please contact Allison Madson, manager of regulatory affairs, at 703-591-2220 or amadson@ascrs.org

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