October 5, 2020

APMA submitted comments to CMS on October 2 to express significant concerns with a proposed rule for revisions to payment policies under the Physician Fee Schedule and Other Revisions to Part B for Calendar Year 2021, as well as comment on proposed changes to the Quality Payment Program (QPP).

Of note, while CMS estimates that some specialties will see a -10 percent or higher adjustment in reimbursement due to the changes in conversion factor and other policies, CMS anticipates only a -1 percent adjustment for podiatrists. Furthermore, APMA expects that with the negative adjustment for high utilization codes such as 11721, most podiatrists should expect to see an overall increase in Medicare reimbursement given that with the new E/M policies, more podiatrists will likely code level 4 and level 5 codes. Below are some of APMA’s higher-priority comments and requests related to the proposed MPFS changes:

1. APMA urged CMS to pursue opportunities to mitigate the impact of the budget neutrality adjustment as related to the proposed conversion factor (which is leading to significantly reduced reimbursement for certain surgical codes like CPT 11721), including pursuing any available PHE authorities and working with Congress to enact a legislative remedy, while preserving the changes to the office/outpatient E/M codes that have previously been finalized for 2021;
2. APMA urged CMS to postpone implementation of the GPC1X E/M add-on code and allow the CPT Editorial Panel to better define the code.
3. APMA requested that CMS allow certain services to be provided via telehealth permanently outside of the public health emergency, expressing our concern that not doing so will perpetuate burdens on physicians and/or patients by requiring patients to travel to a provider’s office or requiring a provider to travel to a patient’s nursing facility, home, or domiciliary setting for a condition that could have been safely and thoroughly treated using telehealth; and
4. APMA requested that CMS work with Congress to remove the telehealth statutory geographic and site of service originating site restrictions.

With regard to proposed changes to the QPP for 2021, APMA commented on the following:

1. APMA requested that CMS consider an automatic neutral adjustment for any 2020 PY MIPS eligible clinician who does not submit data, even if they have not submitted a hardship application;
2. APMA supported the delay of the MVP implementation to at least the 2022 performance year, and recommended that CMS consider delaying implementation further to the 2023;
3. APMA requested simplification and clarification for the APM Performance Pathway (APP), especially as related to the scoring for the quality and improvement performance categories  scoring; and
4. APMA requested that the Cost category remain at 15 percent.

Read the full comment letter at www.apma.org/commentletters.

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