Proposed 2020 Fee Schedule Sees Bump in Payment, Streamlining of Documentation

There will be a slight increase to the “conversion factor” by which relative value units (RVUs) are translated into dollars, from $36.04 per RVU to $36.09 per RVU. This, in combination with other proposed changes, will increase the total allowed charges for psychiatry (and the total overall amount paid to psychiatrists) by 1%. How that will play out for individual psychiatrists will depend on their patient mix and practice type. (RVUs are composed of the values for physician work, practice expense, and malpractice costs associated with every billable code. The RVUs are established by the Relative Value Update Committee, or RUC, which includes representatives from APA.)

CMS proposes requiring performance and documentation of a patient history and exam only as medically appropriate; further, the agency proposes allowing clinicians to bill the E/M visit based on either the level/amount of medical decision-making involved or on the amount of time spent providing care. (The latter proposal removes the requirement that—in order to bill by time—at least 50% of the time must be spent in counseling and coordination of care.)

CMS is removing the requirement that physicians re-document information entered by other members of a clinical team and proposes allowing physicians to document they have reviewed the information rather than requiring them to restate it.

CMS is proposing to add to the suite of Care Management Services a new code that describes Principle Care Management Services. This would pay for care management activities that physicians, including psychiatrists, provide to patients with a single, high-risk, or chronic condition. (Care Management Services is a broad term for activities that physicians or their staff do on behalf of patients when the patient is not in a face-to-face clinical encounter. Until recently, Medicare paid for only a limited set of activities that occurred when the patient was not in the office, and the agency is now proposing to add another code to the options available.)

CMS is also proposing several changes related to care of individuals with OUD. These include a proposal to establish bundled weekly payments for services, including medication, provided by opioid treatment programs, a treatment setting whose services have not been covered by Medicare.

CMS has also proposed a set of bundled monthly payments for services provided to patients with OUD who are receiving care in the office or outpatient setting. APA staff will continue to review these to ensure that the appropriate range of services is included and reimbursed at a sufficient rate.