2020 Medicare Physician Fee Schedule (MPFS) Proposed Rule Released


ASCRS, AAO Secure Equitable Cataract Reimbursements

Proposes ASCRS and Surgical Community-Opposed 
E/M RUC Values for CY 2021

Includes 2020 Quality Payment Program Proposals that Reflect ASCRS and Medical Community Advocacy

Proposed 2020 Conversion Factor: $36.09

On July 29th, CMS released the CY 2020 MPFS Proposed Rule, which will be published in the Federal Register on August 14, 2019, with a 60-day comment period. ASCRS will be submitting comments. CMS also released a fact sheet and press release on this proposed rule.

2020 MPFS Conversion Factor 
The CY 2020 proposed MPFS conversion factor is $36.09, which reflects the 0.14% budget neutrality adjustment and the 0.00% update adjustment factor as established in MACRA. 


ASCRS, AAO Secure Equitable Cataract Reimbursements
ASCRS partnered with the American Academy of Ophthalmology (AAO) in an exhaustive effort to retain reasonable cataract reimbursement for our profession.

CMS today agreed to the rate that the AMA's Relative Value Scale Update Committee (RUC) submitted. Although this is a decrease, the rate is equitable relative to payments of other physician services of similar time and intensity. It is the recommendation to which the ASCRS and AAO agreed.

The RUC is a unique multispecialty committee dedicated to describing the resources required to provide physician services which CMS considers in developing Relative Value Units (RVUs).

In a process that began last year, ASCRS and AAO negotiated with the RUC for a rate that is based on our members’ survey data.

This extensive survey delivered to the RUC a robust data set culled from practicing ophthalmologists. It was combined with careful, sustained negotiations with the RUC. CMS accepted this recommendation for its proposed fee schedule for 2020.

Despite the decrease, cataract surgery remains valued at the very top of the scale when compared with procedures of similar length. This is an acknowledgement of intraocular surgery’s unique intensity and complexity.

Proposed Work RVUs for Cataract Surgery Codes:

CPT Code Current Work RVU  Proposed Work RVU Potential Impact
66982 11.08 10.25  $47 reduction
66984 8.52 7.35  $97 reduction

For additional background and ASCRS perspective click here.


E/M Payment and Documentation

Following opposition from ASCRS and the entire medical community to its E/M proposals included in the CY 2019 rule, CMS delayed its implementation of payment changes to office visit codes until 2021 to allow time for the medical community to revalue the codes through the AMA's CPT and RUC process. ASCRS participated in the process but joined with the surgical community and ultimately opposed the RUC-recommended values due to the potential impact the higher values could have across the fee schedule.

In this proposed rule, CMS is proposing to implement the RUC-recommended E/M values for CY 2021, which are substantially higher than the current values. ASCRS and the surgical community will be advocating in opposition to these increases in the final rule to mitigate the impact on surgical codes and other services across the fee schedule. 

Despite the increase to E/M values, CMS is not proposing to extend these values to the post-operative office visits included in global surgery bundled payments. 

CMS is also proposing to implement ASCRS-supported CPT updates to E/M visits for 2021, which retain 5 levels of coding for established patients, reduce the number of levels to 4 for new patients, and revise the code definitions. The CPT changes also revise the times and medical decision-making process for all of the codes, and require performance of history and exam only as medically appropriate. The CPT code changes also allow clinicians to choose the E/M visit level based on either medical decision-making or time. 


Quality Payment Program

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

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

  • Increasing the MIPS performance threshold from 30 points in 2019 to 45 points in 2020 and proposing to set the threshold at 60 points in 2021. 
  • Increasing the exceptional performance threshold from 75 points in 2019 to 80 points in 2020 and 85 points in 2021.
  • Revising category weights for Quality (decreases from 45% 2019 to 40% in 2020) and Cost (increases from 15% in 2019 to 20% in 2020).
  • 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.

In addition, following ASCRS and medical community advocacy to streamline the MIPS program, CMS is proposing a new participation pathway: MIPS Value Pathways (MVPs), beginning in the 2021 performance year. CMS is seeking to move toward an aligned set of measure options more relevant to a clinician’s scope of practice that is meaningful to patient care. The MVP framework would aim to align and connect measures and activities across the Quality, Cost, Promoting Interoperability, and Improvement Activities performance categories of MIPS for different specialties or conditions. CMS is seeking comment on this concept to begin in 2021 and has not formally proposed any pathways; however, CMS does use ophthalmology as an example, incorporating cataract surgery measures as well as general ophthalmology measures. ASCRS will be providing comment on this provision.

Despite ASCRS and ophthalmic community advocacy, CMS is proposing to 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 Details to Come
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.