Evaluation & Management Coding Changes in the 2021 Physician Fee Schedule Final Rule

On Dec. 1, the Centers for Medicare & Medicaid Services (CMS) released the calendar year (CY) 2021 Medicare Physician Fee Schedule (PFS). One of the key takeaways is the implementation of the American Medical Association (AMA) Relative Value Update Committee’s (RUC) recommended increases in the values of outpatient evaluation and management (E/M) services. This finalized policy marks the most significant update to the E/M Current Procedural Terminology (CPT) codes in approximately 30 years. The agency believes these key changes will reduce the burden on physicians who are required to follow the current coding point system and reward providers for time spent evaluating and managing patients.

CY 2021 Conversion Factor
Although the payment increase for office and outpatient face-to-face E/M visits will go into effect on Jan. 1, 2021, as required by law to account for changes in the relative value updates, the final CY 2021 physician fee schedule conversion factor will be $32.41, a $3.68 decrease from $36.09 in CY 2020.

Telehealth & Other Services/Communications Technology
The CMS finalized on a permanent basis some additional telehealth provisions included in the CY 2021 PFS as a result of the COVID-19 public health emergency (PHE), as well as other provisional services through the end of the PHE. Unfortunately, in the absence of the COVID-19 PHE declaration, the CMS will not continue to recognize audio-only codes that were added in response to the COVID-19 PHE. However, based on comments received, it is establishing a new Healthcare Common Procedure Coding System (HCPCS) code, G2252, describing 11-20 minutes of extended medical discussion. Additionally, the CMS also specifies that the telehealth restrictions will not apply when a beneficiary and practitioner are in the same location, even if conducted via audio/video technology.

The final rule also kept the provision that licensed clinical social workers, clinical psychologists, physical therapists, occupational therapists and speech-language pathologists can deliver brief online assessment and management services, as well as virtual check-ins and remote evaluation services. The final rule includes two new HCPCS codes, G2010 and G2012, to support billing for these telehealth services.

Direct Supervision by Interactive Telecommunications
In the CY 2021 PFS rule, the CMS will continue to cover services that meet incident-to guidelines via telehealth under direct supervision of the billing practitioner. The agency will allow direct supervision to be provided using real-time, interactive audio and video technology through the end of the calendar year in which the PHE ends or Dec. 31, 2021, whichever is later. This provision will allow beneficiaries to receive care by allowing direct supervision through virtual presence while adhering to patient safety and clinical appropriateness. The CMS also indicated it will continue to monitor increased utilization, fraud, waste and abuse and it encourages continued education on incident-to guidelines for providers.