On August 4, 2020, The Center for Medicare and Medicaid Services (CMS) released the MPFS Proposed rule with policy, payment, and coding changes that will impact Medicare Part B providers beginning in 2021.
Within the MPFS Proposed Rule, there are several major areas of impact for home-based primary care providers that warrant advocacy by the field of home-centered care. The policy concerns include the following:
Redefining Evaluation and Management (E/M) Codes and Levels: In the efforts of CMS to ensure accurate reimbursement for E/M codes and support primary care, significant coding changes exclusive to the office visit E/M codes will be starting in 2021. In addition to relieving the documentation burden for the office visit CPT codes (i.e., 99201-99215), CMS is revaluing these codes, which due to the budget neutrality rule, would result in an average negative 10% payment reduction to home and domiciliary CPT codes, if not changed by further rulemaking.
Access to Telehealth Services: The MPFS Proposed Rule clarifies that, under the current statutory limitations, the home is not an approved originating site for Medicare telehealth services. The exception to the current legislation is under the SUPPORT Act; the home is a permissible originating site but only for the treatment of mental health and substance abuse disorders. However, there are promising bills underway to remove these statutory requirements. The complete levels of service for the home and domiciliary CPT codes are not included under Medicare’s proposed Category 1 Telehealth Services, which would remain permanent after the Public Health Emergency (PHE) ends.