CMS Releases Proposed Rules for 2020

Calendar Year 2020 Medicare Physician Fee Schedule Proposed Rule

On July 29, 2019, the Centers for Medicare and Medicaid Services (CMS) released the 2020 Medicare Physician Fee Schedule (MPFS) Proposed Rule. In this rule, CMS describes changes to payment provisions effective January 1, 2020.

Conversion Factor

CMS estimates a CY 2020 conversion factor of $36.0896, which is a slight increase from the current conversion factor of $36.0391.

Changes to Direct PE Inputs for Specific Services

Market-Based Supply and Equipment Pricing Update

For CY 2019, CMS contracted with StrategyGen to review and update the pricing for direct practice expense supply and equipment inputs. This yielded a report with pricing recommendations for approximately 1300 supply and 750 equipment items. While StrategyGen’s findings indicated that the average commercial price for these inputs has remained relatively stable, some medical specialties would experience increases or decreases in their Medicare payments if the changes were adopted. For this reason, a four-year phase-in of the new pricing was proposed.

CMS received many comments following its CY2019 proposed rule, with many concerns about the accuracy of the supply and equipment updated pricing. For those items, StrategyGen conducted further research to confirm that the pricing was appropriate. Submitted invoices were also accepted for review and consideration. Following this additional review, approximately 70 supply and equipment items had their prices further updated. Two of those items include the ultrasound room and the vascular ultrasound room, which both yielded a higher price than previously recommended by StrategyGen. The proposed new pricing for the ultrasound room is $410,303.32, which increased from $369,945.00. The proposed new pricing for the vascular ultrasound room is $479,753.32, increased from $466,492.00.

2020 Proposed

HCPCS	Short Description	Short Description	Non-Facility PE RVUs (PFS)	Malpractice RVUs (PFS)	Total Non-Facility RVUs	PFS Payment Rate (Using 2020 Conversion Factor: $36.0896)
93880 - TC	Extracranial study	0	4.46	0.02	4.48	$161.68
93882 - TC	Extracranial study	0	2.88	0.02	2.9	$104.66
93886 - TC	Intracranial study	0	6.16	0.02	6.18	$223.03
93888 - TC	Intracranial study	0	3.73	0.02	3.75	$135.34
93890 - TC	Tcd, vasoreactivity study	0	6.24	0.04	6.28	$226.64
93892 - TC	Tcd, emboli detect w/o inj	0	6.95	0.04	6.99	$252.27
93893 - TC	Tcd, emboli detect w/o inj	0	8.02	0.04	8.06	$290.88
93925 - TC	Lower extremity study	0	5.6	0.02	5.62	$202.82
93926 - TC	Lower extremity study	0	3.26	0.02	3.28	$118.37
93930 - TC	Upper extremity study	0	4.64	0.04	4.68	$168.90
93931 - TC	Upper extremity study	0	2.9	0.02	2.92	$105.38
93970 - TC	Extremity study	0	4.49	0.02	4.51	$162.76
93971 - TC	Extremity study	0	2.79	0.01	2.8	$101.05
93975 - TC	Vascular study	0	6.14	0.04	6.18	$223.03
93976 - TC	Vascular study	0	3.47	0.02	3.49	$125.95
93978 - TC	Vascular study	0	4.15	0.02	4.17	$150.49
93979 - TC	Vascular study	0	2.68	0.02	2.7	$97.44
93980 - TC	Penile vascular study	0	1.69	0.01	1.7	$61.35
93981 - TC	Penile vascular study	0	1.45	0.01	1.46	$52.69
93990 - TC	Doppler flow testing	0	3.64	0.02	3.66	$132.09
76706 - TC	Ultrasound exam aaa screen	0	2.42	0.01	2.43	$87.70

Calendar Year 2020 Hospital Outpatient Prospective Payment System Proposed Rule

On July 29, 2019, the Centers for Medicare and Medicaid Services (CMS) released the calendar year (CY) 2020 Hospital Outpatient Prospective Payment System (HOPPS) Proposed Rule. This rule provides for a 60-day comment period ending on September 27, 2019. The finalized changes will appear in the final rule in early November and are effective January 1, 2019.

CMS Proposed APC Placement for New CPT Codes

G0365 is being replaced with these new CPT codes:

CPT Code	Description	SVS Recommendation APC Placement	CMS Proposed APC Placement	CY 2020 Proposed Payment Rate
93X00	Duplex scan of arterial inflow and venous outflow for preoperative vessel assessment prior to creation of hemodialysis access; complete bilateral study	5523	5522	$111.04
93X01	Duplex scan of arterial inflow and venous outflow for preoperative vessel assessment prior to creation of hemodialysis access; complete unilateral study	5522	5522	$111.04

Imaging APCs

CMS does not propose any changes to the APC structure for imaging codes. The majority of our codes fall in these 2 APCs.

APC	Groups Title	Status Indicator	CY 2019 Payment Rate	CY 2020 Proposed Payment Rate	CY 2020 Final Payment Rate
5522	Level 2 Imaging without Contrast	S*	$112.511	$111.04	$112.07
5523	Level 3 Imaging without Contrast	S*	$230.56	$231.28	$233.01

* Procedure or service, not discounted when multiple; Paid under OPPS; separate APC payment

The SVU Advocacy Committee is working with our regulatory counsel at Sidley Austin, LLP to review the proposed rules and will draft comments during the 60-day comment period. These comments are due to CMS by September 27th.