MEDICARE PHYSICIAN FEE SCHEDULE FINAL RULE
CMS released the 2021 Medicare Physician Fee Schedule final rule on December 1, 2020 which, despite pressure from healthcare providers and members of Congress, included a 10.2% decrease from the 2020 conversion factor. In addition, CMS finalized adjustments to the RVUs for several CPT codes commonly used by therapy providers including:
CMS also made adjustments to several work, practice expense, and malpractice GPCIs. Taking into consideration the adjustments to the conversion factor and RVUs, the overall impact to therapy providers was estimated to be roughly -9%, depending on the discipline (PT/OT), locality, and ratio of therapy evaluations to procedure codes.
On December 21st, Congress passed legislation which reduced, but did not entirely eliminate, the scheduled cuts. In addition to the fee schedule adjustments, the legislation also extended the temporary suspension of the Medicare sequestration through March 31st, 2021 and extended the Work Geographic Index floor minimum of 1.000 until January 1st, 2024. CMS published the revised 2021 conversion factor (34.8931) as well as the updated RVU and GPCI files the week of January 4th. The final impact to therapy providers for 2021 has been estimated to be roughly -3.0% depending on the locality and billing practices of the provider, a considerable decrease from the -9% reduction originally included in the final rule.
Additional highlights from the 2021 MPFS Final Rule
NCCI EDITS
Over the course of the past year, CMS has implemented several additions, deletions, and reversals to the CCI edit list that have had an impact on therapy providers. Thankfully, the most recent changes that are effective as of 1/1/21 include some welcome deletions of code pair edits that have historically created reimbursement and denial issues, especially with commercial payors.
Of particular interest to therapy providers is the deletion of the edit for the 97140/97530 pairing as well as the deletion of the edits for 97140 when billed with any eval code (97161, 97162, 97163, 97165, 97166, and 97167). In addition, many of the edits associated with the re-evaluation codes (97164 and 97168) have been deleted including pairings with commonly used codes 97110, 97112, 97113, 97116, 97140, 97150, and 97530. However, not all of the edits associated with the re-evaluation codes were deleted. The -59 modifier will still need to be applied when re-evaluation codes are billed on the same date of service as several modality, wound care, and orthotic management codes.
IRG has once again updated its “-59 Modifier Quick Reference Guide” and distributed it to all clinics to assist clinicians as they navigate the latest round of edit updates. Providers can view the full list of CCI edits here.
PT COMPACT
Twenty states are currently issuing and accepting physical therapy compact privileges including Arizona, Arkansas, Colorado, Iowa, Kentucky, Louisiana, Mississippi, Missouri, Nebraska, New Hampshire, North Carolina, North Dakota, Oklahoma, Oregon, Tennessee, Texas, Utah, Virginia, Washington, and West Virginia.
Another nine states have enacted compact legislation but have yet to begin issuing or accepting compact privileges including Delaware, Georgia, Maryland, Montana, New Jersey, Pennsylvania, South Carolina, South Dakota, and Wisconsin.
APPENDIX
Applicable 2021 Registry Quality Measures for PTs and OTs
The hand is a complex and delicate part of our body that we use for…
With the year coming to a close and the publishing of the 2021 Medicare Physician…
The Physical Therapy Compact Commission announced on March 2nd that compact privileges will be available…
Palmetto GBA has published communication to providers regarding the NCCI Procedure-to-Procedure (PTP) Edit Replacement Files. …
As part of the final 2020 Medicare Physician Fee Schedule Rule published in November, CMS…
The relaunch of AIM Specialty Health’s Rehabilitation Program for Anthem Commercial Colorado and Nevada membership…