On Thursday, Nov. 1, the Centers for Medicare & Medicaid Services (CMS) released its final rule, which finalizes changes to the 2019 Medicare Physician Fee Schedule (PFS) and determines the final policies for year three of the Quality Payment Program (QPP).
The AASM is in the process of performing a complete analysis of the publication but provides this alert to highlight a few changes that are particularly important for members.
Reduced work RVUs for three Home Sleep Apnea Test (HSAT) codes
In response to CMS proposing to reduce the work RVUs for the three HSAT codes (95800, 95801, 95806), the AASM sent a letter to CMS expressing strong opposition to this proposal. The AASM also collaborated with the American Academy of Neurology (AAN), American College of Chest Physicians (CHEST), and the American Thoracic Society (ATS) to provide comments to the American Medical Association (AMA) expressing our strong disagreement with the decreased work RVUs. Overall, CMS rejected 29 percent of the recommendations made by the AMA/Specialty Society Relative Value Scale Update Committee (RUC). The AASM comments were included in a RUC comment letter to CMS, which urged CMS to accept the RUC-recommended values. A separate letter from the AMA also urged CMS to adopt all the recommendations made by the RUC. Despite these efforts, CMS has finalized the reduced work RVUs for the three HSAT codes shown below:
95800: Sleep study, unattended, simultaneous recording; heart rate, oxygen saturation, respiratory analysis (e.g., by airflow or peripheral arterial tone), and sleep time
2018 Work RVU: 1.05
2019 Work RVU: 0.85
95801: Sleep study, unattended, simultaneous recording; minimum heart rate, oxygen saturation, and respiratory analysis (e.g., by airflow or peripheral arterial tone)
2018 Work RVU: 1.00
2019 Work RVU: 0.85
95806: Sleep study, unattended, simultaneous recording of heart rate, oxygen saturation, respiratory airflow, and respiratory effort (e.g., thoracoabdominal movement)
2018 Work RVU: 1.25
2019 Work RVU: 0.93
2019 Physician Fee Schedule Conversion Factor
The 2019 conversion factor was increased to 36.0391. This is approximately a $0.04 increase from the 2018 conversion factor of 35.9996, which results in a slight increase in payment for most sleep procedures and evaluation and management codes. Given that the conversion factor was not changed significantly, reimbursements for most sleep services other than HSAT will remain fairly consistent with 2018 levels. A complete analysis of the impact on sleep services will be shared soon in an updated AASM Sleep Medicine Payment and RVU Comparison document.
Potential changes to Evaluation and Management documentation guidelines and codes
The AASM comment letter to CMS also expressed disagreement with the CMS proposal to collapse payment rates for new and established patients. Instead the AASM encouraged CMS to support the newly created AMA E/M Workgroup focused on developing an alternative to the current E/M codes and payment rates. AASM also signed onto a letter submitted to CMS by the AMA on behalf of 170 organizations, requesting time for the AMA Workgroup to identify solutions to the current issues with E/M coding and payment, for potential implementation in 2020. Within the final rule, CMS delayed implementation of changes to the E/M documentation guidelines, coding and reimbursement until 2021. This gives the E/M Workgroup time to solidify proposed solutions to submit to CMS for consideration.
The AASM will perform a full analysis of the final rule and inform members of relevant revisions in the 2019 PFS and QPP programs.
Please send any questions about the Medicare Physician Fee Schedule final rule to firstname.lastname@example.org.