News: FY 2020 OPPS proposed rule released

CMS recently released the calendar year (CY) 2020 Medicare Physician Fee Schedule (MPFS) and outpatient prospective payment system (OPPS) proposed rules, introducing new current procedure terminology (CPT) codes and extensive changes to documentation requirements for evaluation and management (E/M) office visits, and seeking commentary on how to overhaul the merit-based incentive payment system (MIPS) and undo its payment policy for drugs purchased through the 340B drug discount program, JustCoding reported.

In the MPFS, CMS proposes not to include blended payment rates for office E/M services based on stakeholder feedback along with changes to E/M documentation requirements and reporting policies for 2021 implementation including:

• Separate payments rates for E/M codes 99201-99215, instead of a single amount for Levels 2 to 4, as had been previously proposed
• Updated E/M valuations that would increase payment for outpatient E/M visits
• Significantly revised E/M documentation guidelines: Providers would be allowed to select a service based on medical decision-making or time and would no longer have to factor in history and examination elements

Additionally, CMS included information on more than 100 new CPT codes, effective for reporting in 2020.

CMS also requested commentary and feedback on a new MIPS framework called the MIPS Value Pathways (MVP), intended to simplify quality reporting requirements. For reporting in 2021, MVP would move MIPS from its current state, which requires providers to report on many measures across multiple performance categories, to a system in which providers would report on a smaller set of specialty-specific measures, according to JustCoding.

More detailed information on the changes can be found here.

In the 2020 OPPS proposed rule, CMS asked for comments on how to potentially undo its policy that reduced payments for drugs purchased under the 340B drug discount program by nearly 30% and proposes to move forward with year two of the site-neutral payment policy for clinic visits.  

CMS said that they intend to complete the second year of a policy to reduce reimbursement for clinic visits in off-campus provider-based departments (PBD) previously protected from CMS’ PBD reimbursement reduction, claiming “unnecessary increases” in outpatient service volume, according to JustCoding.

In the 2019 OPPS final rule, CMS instituted a policy to pay providers the equivalent of 70% of the OPPS rate for the services described by HCPCS code G0463 (hospital outpatient clinic visit for assessment and management of a patient) in 2019. In that same rule, CMS noted its intention to reduce that payment to 40% of the OPPS rate for 2020 and subsequent years.

In the 2020 OPPS proposed rule, CMS says it is completing the second phase of this price reduction to “reduce unnecessary utilization” and save beneficiaries an average of $14 each time they visit an off-campus PBD for a clinic visit.

More detailed information on the OPPS changes can be found here.

Editor’s note: To read JustCoding’s extended coverage of the proposed rule, click here. To read more about site neutral payments, click here.