On July 29, the Centers for Medicare & Medicaid Services (CMS) released the 2020 Proposed Rule summarizing proposed revisions to the Physician Fee Schedule and Quality Payment Program. Many of the proposals included in the rule continue to prioritize the Patients Over Paperwork initiative, created to reduce administrative burden as much as possible.

AASM staff performed an analysis of the CMS 2020 Physician Fee Schedule and Quality Payment Program 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). The AASM previously reported that the conversion factor for calendar year 2020 is proposed to increase slightly to $36.09.

AASM submitted a comment letter to CMS on behalf of all individual and sleep facility members. Key highlights from the AASM comments include:

  • Support for the efforts of CMS to develop a more comprehensive dataset for the development of Professional Liability Insurance Relative Value Units (RVUs), along with encouragement to implement methodologies that ensure data are as accurate as possible for all specialties
  • Overall support for aligning physician assistant (PA) scope of practice regulations with state scope of practice laws, while recommending a modification to the proposed language to ensure that PA services are not provided independent of physician oversight
  • Support for the proposal to establish a general principle to allow the physician, the PA, or the advanced practice registered nurse (APRN) who furnishes and bills for their professional services to review and verify, rather than re-document information included in the medical record by other members of the medical team, consistent with the Patients over Paperwork initiative
  • In response to a comment solicitation on consent for communication technology-based services, AASM recommended that CMS revise the current requirement to obtain and document patient consent for every visit, to allow for documentation of patient consent on an annual basis in the medical record, to reduce administrative burden.
  • Support for the proposal for CMS to consider per-beneficiary payments for condition-specific episodes of care, if episodes are developed by or with the input of appropriate medical specialties
  • Support for the AMA E/M Workgroup recommendations for Evaluation and Management (E/M) coding changes, including reducing the new patient office visit levels to four by eliminating code 99201 and revising the code definitions and guidelines
  • Several recommendations in response to the MIPS Value Pathways Request for Information, supporting the concept of more streamlined and cohesive reporting, and in strong opposition to a complete overhaul of the MIPS program

AASM comments were submitted Sept. 27. All comments received in response to the Proposed Rule will be reviewed by CMS in advance of publication of the Final Rule later this fall. 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 sleep care to Medicare patients.

Find more coding and reimbursement resources from the AASM.