2021 Medicare Physician Fee Schedule (PFS) Summary

The Centers for Medicare and Medicaid Services (CMS) issued for public inspection on August 4 the proposed rule on the 2021 PFS. While the proposed rule is typically published in early July each year, the COVID-19 public health emergency (PHE) has significantly delayed the process.  Given this delay, the publication of the 2021 final PFS rule also will likely be delayed; however, the final rule provisions will still be implemented and effective on January 1, 2021.

Conversion Factor

Overall, the proposed calendar year (CY) 2021 PFS conversion factor is $32.26, which is a decrease of $3.83 from the CY 2020 PFS conversion factor of $36.09. The estimated impact to audiology is -7 percent. This is due to policy changes that are beyond the control of the Academy, specifically the budget neutrality adjustment to account for changes in relative value units (RVUs), as required by law. A list of the proposed payment updates for audiology codes is available.  

New Audiology Codes Values Released

The Academy celebrates the successful development of eight new codes through the CPT process and the presentation for valuation in the RUC process last year leading now to acceptance and release by CMS.

• Auditory-Evoked Potentials (CPT codes 92584, 92X51, 92X52, 92X53, and 92X54)To better describe tests of auditory function, the American Medical Association (AMA) Current Procedural Terminology (CPT) Panel created CPT code 92584 (Electrocochleography) and replaced CPT codes 92585 and 92586 with four new services. CMS is proposing to accept the RUC-recommended work RVUs of 1.00 for CPT code 92584, 1.00 for CPT code 92X52 (Auditory-evoked potentials; for hearing status determination, broadband stimuli, with interpretation and report), 1.50 for CPT code 92X53 (Auditory evoked potentials; for threshold estimation at multiple frequencies, with interpretation and report), and 1.05 for CPT code 92X54 (Auditory-evoked potentials; neurodiagnostic, with interpretation and report). CPT code 92X51 (Auditory- evoked potentials; screening of auditory potential with broadband stimuli, automated analysis) is a screening service and is not payable by Medicare. Therefore, CMS is not proposing a valuation for this code but will display the RUC-recommended work RVU of 0.25.
• Vestibular-Evoked Myogenic Potential Testing (CPT codes 925X1, 925X2, and 925X3)CPT code 925X1 (Vestibular-evoked myogenic potential testing, with interpretation and report; cervical (cVEMP)); CPT code 925X2 (Vestibular evoked myogenic potential testing, with interpretation and report; ocular (oVEMP)); and CPT code 925X3 (Vestibular evoked myogenic potential testing, with interpretation and report; cervical and ocular). CMS accepted RUC-recommended work RVU of 0.80 for CPT codes 925X1 and 925X2. For CPT code 925X3, CMS is also proposing the RUC-recommended work RVU of 1.20. CMS is also proposing the RUC-recommended direct PE inputs without refinement for these three VEMP codes.

CMS Proposes a New Way to Add Services to the Telehealth List on a Temporary Basis

CMS proposes to create a new category of criteria for adding services to the Medicare telehealth services list on a temporary basis that would include the services that were added during the PHE for which there is likely to be clinical benefit when furnished via telehealth, but for which there is not yet sufficient evidence available to consider the services as permanent additions under existing categories. This will give the public the opportunity to gather data and generate requests to add certain services to the Medicare telehealth services list permanently.  Finally, CMS proposes that telehealth services authorized under the PHE be extended until the end of 2021.

CMS Affirms CPT 2021 E/M Changes

CMS generally accepts the new E/M code and guideline changes for CPT 2021.  CMS has proposed using two new HCPCS G codes to allow for some providers, including speech-language pathologists, to furnish brief online assessment and management services. Audiologists do not currently have the ability to bill for E&M services, and the Academy will continue to explore pathways for inclusion of audiologists in the new E/M guidance. The Academy also continues to partner with other provider types negatively impacted by the cuts to pursue legislation to address payment reductions.

Merit-Based Incentive Payment System (MIPS)

Audiologists who are required to participate in the Quality Payment Program (QPP) typically choose the MIPS pathway to report quality measures.  Under the proposed rule for 2021, CMS proposes to retain current quality measures (9) for reporting. These are:

• #130 – Documentation of Current Medications in the Medical Record
• #134 – Preventive Care and Screening: Screening for Depression and Follow-Up Plan
• #154 – Falls: Risk Assessment
• #155 – Falls: Plan of Care
• #181 – Elder Maltreatment Screen and Follow-Up Plan
• #182 – Functional Outcome Assessment
• #226 – Preventive Care and Screening: Tobacco Use: Screening and Cessation Intervention
• #261 – Referral for Otologic Evaluation for Patients with Acute or Chronic Dizziness
• #318 – Falls: Screening for Future Fall Risk

CMS notes the audiology specialty set takes into account whether the measure reflects current clinical guidelines and the coding of the measure includes relevant clinician types, and states it may reassess the appropriateness of individual measures, on a case-by-case basis, to ensure appropriate inclusion in the specialty set.

CMS Delays MIPS Value Pathways (MVPs) to 2022

The new MVPs framework was slated to begin with the 2021 performance period. However, CMS now states the MVPs program will not be available for MIPS reporting until the 2022 performance period, or later.  In addition, CMS proposes slightly modified goals for the MVP program to ensure clinical efficiencies and better reflect the needs of patients. 

The modified goals are

1. MVPs should consist of limited, connected, complementary sets of measures and activities that are meaningful to clinicians, which will reduce clinician burden, align scoring, and lead to sufficient comparative data. 
2. MVPs should include measures and activities that would result in providing comparative performance data that is valuable to patients and caregivers in evaluating clinician performance and making choices about their care; MVPs will enhance this comparative performance data as they allow subgroup reporting that comprehensively reflects the services provided by multispecialty groups. 
3.  MVPs should include measures selected using the Meaningful Measures approach and, wherever possible, the patient voice.

Additional Resources

• Fact Sheet on the CY 2021 Physician Fee Schedule Proposed Rule
• Fact Sheet on the CY 2021 Quality Payment Program Proposed Rule
• CY 2021 Physician Fee Schedule and Quality Payment Program Proposed Rule
• Proposed Payment Updates for Audiology Codes

The Academy will continue to analyze the proposed 2021 PFS. We will provide comments to CMS by the October 5, 2020, deadline.