2019 Medicare Physician Fee Schedule (PFS) Final Rule

Note from Mark Isenberg, EVP Health Advocacy:

While the final rule is not exactly what we supported and advocated for, we are reasonably pleased with the direction CMS elected to take in their final rule with comment. Through coordinated lobby and advocacy efforts on behalf of our clients, ZP was able to work with specialty societies to effectively mobilize physicians and allow their voices to be heard.

We were especially pleased to see that CMS elected not to slash the technical RVU for ultrasound and that they are being more thoughtful on their rollout of the new E&M documentation and bundling initiative. We encourage all our clients to remain active in our advocacy efforts at www.zotecpac.com.

2019 Medicare Physician Fee Schedule (PFS) Final Rule

Thursday, November 1, 2018, the Centers for Medicare & Medicaid Services (CMS) released the final 2019 MPFS Final Rule, which includes changes to the Merit-based Incentive Payment System (MIPS) and Alternative Payment Model (APM) participation options and requirements for the 2019 Quality Payment Program.

Conversion Factor

  • The 2019 MPFS conversion factor is $36.0391 (a very slight increase from 2018's $35.9996).
  • The 2019 anesthesia conversion factor will be set at $22.2730 a slight increase from $22.1887 in 2018.

CMS estimates an overall impact to allowed charges from MPFS final changes as follows:

  • Anesthesiology: 0%
  • Diagnostic Radiology: 0%
  • Interventional Radiology: +2%
  • Diagnostic Testing Facility: -5%
  • Emergency Medicine: 0%
  • Critical Care: -1%
  • Pathology: -2%
  • Radiation Oncology/Therapy Centers: -1%
  • Internal Medicine: 0%
  • Nuclear Medicine: -1%
  • Nurse Practitioners: 0%
  • Physician Assistants: 0%
  • Family Practice: 0%

A few highlights of the Final Rule include:

  • Finalized for 2021, CMS anticipates a single payment rate for levels 2 through 4 Evaluation and Management (EM) office/outpatient visits (one rate for new, and one for established patients) and maintaining separate payment rates for new and established patients for level 5 EM office/outpatient visits. For CY 2019 and CY 2020, CMS will continue the current coding and payment structure for EM office/outpatient visits and practitioners should continue to use either the 1995 or 1997 EM documentation guidelines to document EM office/outpatient visits billed to Medicare. CMS also outlined policies to ease documentation burden during the 2019/2020 period.
  • CMS did not finalize their proposal to apply a multiple procedure payment reduction (MPPR) to EM visits performed on the same day as procedures, i.e., those EM services billed with the -25 modifier.
  • CMS finalized its proposal to change the documentation requirements for teaching physicians (TP) where their services are billed in conjunction with services provided by a resident or fellow but clinical performance standards have not changed. Of note, effective January 1, 2019 the extent of the TP’s participation with the patient may be documented by the TP, resident or nurse.
  • Finalizes new covered codes for technology-based services, including virtual care and remote patient monitoring codes.
  • Appropriate Use Criteria for Certain Imaging Services: CMS reaffirmed claims processing instructions to move forward with implementation of appropriate use criteria (AUC)/clinical decision support (CDS) for all advanced diagnostic imaging services on January 1, 2020.
  • Radiology Assistant Supervision: CMS finalized a revision to the physician supervision requirements so that any diagnostic test performed by a Radiologist Assistant (RA) may be furnished under, at most, a direct level of physician supervision, when performed by an RA in accordance with state law and state scope of practice rules. This will allow tests that normally require personal supervision to be provided under direct physician supervision when performed by a RA.

We will publish more detailed specialty summaries in the coming weeks.

For More Information: