AACU News & Notes

AACU Submits Comments on 2021 Medicare Physician Fee Schedule

posted: October 14, 2020

Proposed Rule an Overall Win for Urology

On October 5, the AACU submitted a formal comment letter to the Centers for Medicare and Medicaid Services (CMS) on the proposed 2021 Medicare Physician Fee Schedule. The association urged CMS to use its authority to waive budget neutrality cuts which will impose severe reductions in payments on physicians who do not report office visit codes.

Overall, the rule included a number of provisions beneficial to Urology, which AACU commented on favorably and urged CMS to include in the final rule. The new fee schedule would allow for an 8% increase in allowed overall charges ($1.803 billion) for urology. The rule also proposes the addition of a new add-on code (GPC1X), supported by AACU, which compensates clinicians for providing non-procedural specialized medical care to complex or outlier patients.

The AACU also strongly supported the proposed expansion of coverage and payment for Telehealth services, including the removal of geographic and site-of-service restrictions and continued payments for audio-only telephone E/M services. The rule would make these waivers permanent while maintaining reimbursement levels that support the infrastructure needed for physicians to continue providing Telehealth services.

Additional recommendations from the AACU included the following:

  • E/M Coding Changes and Relative Value Units (RVUs): The AACU supports CMS’ proposal to adopt coding changes and RVUs for E/M services recommended by the RVS Update Committee (RUC).
  • Global Service Periods: The AACU opposes CMS’ decision to not incorporate the revised office/outpatient E/M values into global surgery payments as it will disrupt the relativity principle within the fee schedule.
  • Telehealth Expansion: The AACU supports changes to originating site requirements and frequency limitations, specifically lifting the rural-only restriction and adding any site where a patient is located as a potential originating site.
  • Category 3 Telehealth Services: The AACU encourages CMS to continue offering Category 3 codes, which allows providers to offer promising new approaches to care before they are authorized for permanent use.
  • Audio-Only Telephone E/M Services: The AACU strongly supports continued payments for telephone E/M visits for patients who need telecommunications-based services in the home but do not have access to or have difficulty with video conferencing.
  • Virtual Supervision of Residents: The AACU recommends that when the PHE concludes, CMS sunset waivers that currently allow non-physician providers to supervise the performance of diagnostic tests to the extent authorized under state scope of practice laws.

Finally, the AACU commented on CMS’ proposed valuation of four CPT codes commonly used by urologists. The agency aligned their valuation on alternate work RVUs instead of the RUC-recommended work RVUs. The AACU urges CMS to use valid survey data, analyzed by the RUC, to establish the correct work RVUs for these four codes.

AACU will continue to advocate on behalf of the urology community until CMS finalizes the 2021 payment rules, expected in early December 2020.

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