On behalf of all individual and facility members, the AASM submitted a comment letter to the Centers for Medicare & Medicaid Services (CMS) on Oct. 5 in response to the CMS 2021 Physician Fee Schedule and Quality Payment Program proposed rule, which was published in the Federal Register in August.
Many of the proposals included in the rule were put forth to explain how significant changes have led to implementation of budget neutrality, including a significantly lower Medicare conversion factor; solicit comments on how long to continue waivers effective during the COVID-19 public health emergency (e.g., telehealth); and reinforce changes to reporting and reimbursement of the evaluation and management (E/M) outpatient office visit codes.
AASM’s health policy team performed an analysis of the proposed rule and found that several of the proposed revisions will impact sleep medicine coding, documentation, reimbursement, and participation in the Merit-based Incentive Payment System (MIPS). Key highlights from the AASM comments include:
- Strong opposition to the implementation of budget neutrality and the proposed Medicare conversion factor $32.26, which could potentially lead to an 11% reduction in reimbursements
- Support for the development of coding and payment for audio only services similar to the virtual check-in, with units of time parallel to the units of time associated with E/M visits, to allow providers the ability to accurately report time as they are able to do during the current public health emergency
- Support for extending the telehealth code list by adding codes that are similar to services currently on the list and for making the Telehealth List Category 3 permanent
- Suggestion that CMS include both existing and new communication technology-based services in Category 3 Medicare Telehealth Services, as these services are similar to face-to face services
- Support for the increase in values for standalone therapy services to reflect the value of office/outpatient E/M visits with the recommendation to apply value increases in office visits uniformly
- Support for making permanent direct supervision using interactive communications technology
- Support for extending the MIPS Extreme and Uncontrollable Circumstances Hardship Exemption policies through the end of 2021 or one year following the end of the current public health emergency
More than 41,000 comments were submitted to CMS in response to the proposed rule and will be reviewed by CMS in advance of publication of the final rule, projected for publication on or around Dec. 1. AASM will review the final rule and keep members informed of all final revisions to the Physician Fee Schedule and Quality Payment Program. AASM continues to advocate on behalf of all individual and facility members to ensure their ability to receive appropriate reimbursement for the continuous provision of high-quality care to sleep medicine patients.