On Nov. 1, 2019, the Centers for Medicare & Medicaid Services (CMS) released the 2020 Medicare Physician Fee Schedule Final Rule, summarizing proposed revisions to the Physician Fee Schedule. AASM staff analyzed the final rule to determine whether CMS finalized proposals that would impact the field of sleep medicine. The AASM previously submitted a response letter to CMS, highlighting specific areas of concern following release of the proposed rule.

Medicare Final Rule Summary

Final determinations on those items are summarized below:

  • CMS finalized a slight increase in the Medicare Conversion Factor for 2020 to $36.09, which will be $0.05 above the 2019 Conversion Factor.
  • The budget neutrality adjustment accounts for changes in relative value units (RVUs) and reimbursement amounts, impacting sleep, evaluation and management (E/M), and telemedicine codes. Changes are detailed in these payment and RVU documents:
  • With support and advocacy from the AASM and other stakeholders, CMS has finalized the recommendations for E/M coding changes for implementation in calendar year 2021. These changes include reducing the new patient office visit levels to four by eliminating code 99201 and revising the code definitions and guidelines to focus on time and medical decision making. The AASM will develop and share resources to educate members on the details of these changes.
  • In response to comments from the AASM and other stakeholders, CMS finalized the consent documentation requirement for Communication Technology Based Services to allow for documentation of patient consent on an annual basis in the medical record, which will reduce administrative burden.
  • CMS finalized the proposal to develop a more comprehensive dataset for the development of Professional Liability Insurance RVUs with several modifications but did not accept the AASM’s recommendation to identify crosswalks for related specialties.
  • The proposal to align physician assistant scope of practice regulations with state scope of practice laws was finalized.
  • Consistent with the Patients over Paperwork Initiative, CMS finalized the proposal to allow the physician, the physician assistant, 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.

More Information

For more information, you can read the 2020 Medicare Physician Fee Schedule Final Rule fact sheet on the CMS website. Members may send questions about the final rule to coding@aasm.org.

Find more Medicare Resources from the AASM.