CMS Releases Final Rule for CY2021 Physician Fees

On December 1, 2020, the Centers for Medicare and Medicaid Services (CMS) released its Final Rule for the calendar year 2021 Medicare Physician Fee Schedule. All changes will go into effect on January 1, 2021. Key topics of interest to HRS members include:

• Payments for extended external cardiac monitoring
• Revised valuations for EP study with left atrial arrhythmia induction (CPT 93621) and Intracardiac echocardiogram (CPT 93662)
• Revisions to the Evaluation and Management (E/M) Office Visit Codes (CPT 99201-99215)
• A decrease in the 2021 Conversion Factor (CF)

HRS submitted comments to CMS on these and other topics in September.

Work Relative Values for New and Existing Cardiac Monitoring Codes

Existing codes for Holter monitoring and new codes for extended external cardiac monitoring were valued by the AMA/Specialty Society Relative Value Scale Update Committee (RUC) in January 2020. The RUC accepted the HRS and the American College of Cardiology (ACC) work value recommendations yet sought clarification on some of the inputs for practice expenses (costs associated with providing a service such as staff time, supplies, and equipment). CMS still has questions about data that was submitted and the codes for cardiac monitoring greater than 48 hours, up to 15 days, will be contractor priced.

CMS also did not accept the recommended work relative values, for CPT codes 93621 and 93662, stating that the work values do not correlate with the decrease in time as captured in physician survey data. The codes had to revalued due to high growth in utilization.

A downloadable spreadsheet of RVUs and average Medicare payments for EP services is available here.

Revisions to the Evaluation and Management Codes

As finalized as part of the CY 2020 fee schedule, in CY 2021 CMS will implement new relative values for the office and outpatient E/M codes (CPT 99202-99215). CPT 99201 will be deleted. CMS will implement increased values for CPT 99202-99215 as previously planned. Spending on these codes alone accounts for approximately 20% of all Medicare Part B expenditures. In addition, CMS will implement HCPCS code GCPX1 for added complexity during an office visit. HRS will provide input on how to improve the code’s description and ensure correct usage.

Reduction in the Conversion Factor (CF)

The CF is the dollar value that translates each CPT code’s relative values into a payment amount. Due to statutorily mandated budget neutrality requirements and the increased spending that results from the revisions to the office and outpatient E/M codes, CMS announced a 10.2% cut to the 2021 Medicare conversion factor. The CY 2020 CF is $36.09 and the CF for FY 2021 is $32.4085. HRS and the entire physician community are working toward legislative action to stop this cut.