HPC Corner: Highlights of Proposed Changes to the 2020 Physician Fee Schedule

By: Melissa Chen, MD     

On July 29, 2019, Centers for Medicare & Medicaid Services (CMS) released the 2020 Proposed Rule1 for the Physician Fee Schedule.  Two areas of proposed changes have the potential to impact reimbursements to neuroradiologists.  New valuations for several code families including Lumbar Puncture, CT orbit-ear-posterior fossa code family, CT spine code family and numerous X-ray codes were proposed.  Additionally, recommended changes to the E&M code structure and valuation slated to take place in 2021 could have a negative impact on the Conversion Factor (CF), ultimately decreasing revenues to neuroradiologists.

The lumbar puncture code recently underwent restructuring and revision by the AMA Current Procedural Terminology (CPT) Editorial Panel with imaging guidance bundled with the procedure.  As part of the code revision process, the RBRVS Update Committee (RUC) valued the code family.  CPT code 70480, CT orbit-ear-posterior-fossa without IV contrast, and CPT code 72132, CT lumbar spine without IV contrast, were identified on a CMS screen of “CMS/Other codes with utilization < 30,000”.  Consistent with the RUC process, the entire code families were surveyed for valuation.

Although CMS accepted some of the RUC-recommended values for these codes, CMS has proposed a decrease in many of the values.  The rationale CMS used for decrease in valuation focused on times from the survey compared to historical times that were derived differently and ignored the relative intensity and complexity of procedures.   The ASNR submitted comments to CMS regarding the valuation of these important neuroradiology codes and urged CMS to accept the RUC-recommended values in order to preserve relativity within the fee schedule.

The most impactful proposed changes are unrelated to neuroradiology or radiology CPT codes.  Last year, a new Evaluation and Management (E/M) code structure was proposed as part of the initiative to reduce provider burnout from CMS administrator, Seema Verma, entitled “Patients over Paperwork”.  In summary, the proposed collapse of the E/M code family from 5 different levels of service to 2 levels was not well-received by physicians and medical societies.  The AMA organized efforts to make recommendations to CMS regarding the code structure, decreased documentation requirements and updated valuation through the CPT and RUC processes; and CMS delayed implementation of the initial proposal.

In the latest proposed rule, CMS accepted the AMA CPT code restructuring and RUC-recommended increase in values for the E/M services (CPT codes 99202-99215).  This included the deletion of the level 1 new patient office/outpatient E/M visit code, CPT code 99201.  Given budget neutrality of physician payments, the increase in payments for E/M services as proposed could result in an estimated 8% reduction in reimbursements to radiology starting in 2021.2 These changes remain a proposal, and CMS typically releases the Final Rule in November.

The AMA CPT and RUC processes remain influential in health policy, and neuroradiologists must stay engaged. Filling out RUC surveys and maintaining your membership in the ASNR and AMA remain vital in these efforts.


1 https://www.govinfo.gov/content/pkg/FR-2019-08-14/pdf/2019-16041.pdf

2 https://www.acr.org/-/media/ACR/NOINDEX/Advocacy/2020-MPFS-PR-Preliminary-Summary-UPDATED.pdf?la=en