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Anesthesia Compliance: How 2020 MPFS will Impact Anesthesiologists

In early summer, the Centers for Medicare and Medicaid Services (CMS) offered anesthesiologists a glimpse at the reforms happening to the Medicare Physician Fee Schedule (MPFS) and the Quality Payment Program (QPP) for the Calendar Year 2020 (CY 2020).

CMS has released its Final Rule on 2020 MFPS policy-payment adjustments and QPP amendments. These changes promise to improve billing accessibility, support patient care, increase affordability and offer modern coding innovation for all anesthesiologists.

After reviewing CMS’ two-thousand page Final Rule, we have summarized the ruling to reveal the top five most important 2020 MPFS and QPP changes that will immediately impact anesthesiology.

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Top 2020 MPFS Changes

Coding Changes

The Final Rule does not add or alter Current Procedural Terminology (CPT) codes for individual anesthesia services. The Rule does include new CPT codes for individual pain procedures and modifies other coding that may apply to anesthesia services linked to pain management.

Relative Value Units (RVU) for somatic nerve injection codes (CPT 64400-64450) will also pay lower next year, meaning you should expect to earn a reduced reimbursement in CY 2020 when performing these procedures. [see pg. 177,Sec. 4(25)]

You should also note that beginning in 2021,  CMS will bundle ultrasonic guidance procedures (CPT 76942) with CPT codes 64400-64450 when performed.

New codes that may affect your anesthesia billing include:

  • CPT 20560 – 20561: Needle insertion without injection (dry needling).
  • CPT 62328: Spinal puncture, lumbar, diagnostic; with fluoroscopic or CT guidance.
  • CPT 62329: Spinal puncture, therapeutic, for drainage of cerebrospinal fluid (by needle or catheter); with fluoroscopic or CT guidance
  • CPT 64454: Injection(s), anesthetic agent(s) and/or steroid, genicular nerve branches, including imaging guidance, when performed.
  • CPT 64624: Destruction by neurolytic agent genicular nerve branches including imaging guidance, when performed.
  • CPT 64451: Injection(s), anesthetic agent(s) and/or steroid; nerves innervating the sacroiliac joint, with image guidance (ie, fluoroscopy or computed tomography).
  • 64625: Radiofrequency ablation, nerves innervating the sacroiliac joint, with image guidance (ie, fluoroscopy or computed tomography).

Revised codes that may affect your anesthesia billing include:

  • CPT 62270: Spinal puncture, lumbar, diagnostic.
  • CPT 62272: Spinal puncture, therapeutic, for drainage of cerebrospinal fluid (by needle or catheter).

Make sure you are using new codes appropriately to ensure anesthesia compliance.

Conversion Factor Adjustments

The National Medicare Anesthesia Conversion Factor (CF) for 2020 has increased minimally by $.01 from 2019 to $22.20. The CF for non-anesthesia services in CY 2020 also increased to $36.09, a $0.05 increase compared to 2019.

However, take note that your actual CF for 2020 will differ
based on locality data obtained from the Geographic Practice Cost Index (GPCI).

While conversion factor adjustments were minimal – the changes could be more significant based on your location.

Relative Value Units (RVU) Revisions

Despite the minimal increases to CF in CY 2020, the ASA advises that revisions to several relative value unit (RVU) components among specialty CPT code sets will not negatively impact your reimbursements. Chronic pain providers, however, may receive an RCU reimbursement increase of one percent.

Changes to Evaluation and Management
Services

In July 2019, CMS was considering modifying payments for Evaluation and Management (E/M) services and would reconsider how anesthesiologists would document the new E/M procedures moving forward.

CMS made good on its promises in the Final Rule by signaling some noteworthy CPT coding adjustments and payment increases for E/M office/outpatient visits over the next two years.

During CY2021, the following E/M coding changes will take place:

  • New Patients: CPT 99201 will be eliminated, reducing the number of code levels from five to four for office/outpatient E/M visits.
  • Established Patients: Code levels will remain at five. However CPT 99211 will only be used for non-physician clinical staff visits.
  • Enhanced E/M services: CMS proposes to establish a new add-on CPT code (GPC1X) to all additional reimbursement for E/M services for patients being treated for serious or complex chronic conditions.

These coding changes will reverse previously proposed E/M rule changes, which set up two levels for established patients and grouped new patients into a single rate.

Alterations to upcoming CY 2021 E/M documentation and reimbursements will likewise include:

  • Introduction of new E/M code descriptors.
  • Separate payment amounts for individual levels of E/M service.
  • Revised “work and practice” expense calculations on RVU billing.
  • Modification of individual E/M “time component” rules.
  • Changes to E/M code selection based upon medical decision-making processes.
  • Demands for documentation of history and exam will be limited to details considered clinically relevant.

Impacts to the Quality Payment Program

Congress enacted the quality payment program (QPP) in 2015 with a resolve to improve quality and cost in anesthesiology services via Merit-Based Incentive Payment System (MIPS) and Alternative Payment Models (APMs).

The CMS’ Final Rule also introduces several technical MIPS amendments. The most important QPP changes that will impact anesthesiologists in CY 2020 and beyond include:

  • Performance threshold points for avoiding negative payment adjustments increase from 30 points to 45 points in CY 2020 and 60 points in CY 2021.
  • Exceptional performance threshold rises to 80 points in CY 2020 and 85 points in CY 2021.
  • Quality performance weight decreases to 40 percent in CY 2020, 35 percent in CY 2021, and 30 percent in CY 2022.
  • Cost performance weight categories increase to 20 percent in CY 2020, 25 percent in CY 2021, and 30 percent in CY 2022.
  • Introduction of MIPS Value Pathways (MVPs) will start in CY 2021 for reporting specialty-specific, outcome-based, smaller measure sets more closely aligned with APM measures.
  • No changes in the low-volume threshold, Eligible Clinician types, MIPS performance periods, and Certified EHR Technology (CEHRT) requirements.
  • The MIPS quality reporting threshold will increase from 60 percent to 70 percent of eligible cases per measure.
  • Implementation of a negative nine percent payment adjustment beginning in 2022 for anesthesiologists who are NOT exempt but fail to participate in MIPS in 2020 or fail to meet the 45-point composite scoring threshold.

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Maintain Anesthesia Compliance with Fusion Anesthesia

Not every anesthesia billing company takes the time and energy to sort through thousands of pages of CMS documentation so that their clients can have the most relevant anesthesia compliance information at their disposal each year—even though they may promise to do so.

Fusion Anesthesia understands the challenges you face to stay compliant, an undertaking that guarantees you’ll collect all your hard-earned Medicare reimbursement dollars on time.

If you’re looking for a partner who offers complete anesthesia management services with comprehensive CMS compliance assistance each calendar year…

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