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CMS Physician Payment Proposed Rule for 2021 and ASC & HOPD Proposed Payment Rates for 2021

Physician Fee Schedule For Calendar Year 2021 – See Comment Letter

CMS has released proposed policy changes to the Medicare physician fee schedule for calendar year 2020 on August 3, 2020 at midnight [ ]. CMS claims that the calendar year 2021 PFS proposed rule is one of several proposed rules that reflect a broader administration – wide strategy to create a health care system that results in better accessibility, quality, affordability, empowerment, and innovation.

For interventional pain management programs for interventional pain management physicians, an overall picture shows that there is a 7% combined impact in reference to the charges by specialty, while many of the other specialties have shown decreases. A few like endocrinology, family practices, general practices, and internal medicine have shown increases.

Consequently, multiple surgical specialists are extremely upset about this payment rule; however, for interventional pain physicians, it has not been that bad.

ASIPP has calculated the proposed preliminary physician payment rates compared to 2020.

Overall physician payment rates have shown declines, specifically, more commonly utilized procedures when performed in a facility setting, meaning ASC or hospital. The cuts are much less when performed in an office setting (non-facility setting). The schedule shows these payments:

Physician payment rule specifically deals with payment updates with reduction in the conversion factor for 2021 of $32.26, down from $36.09 in 2020.

The major reductions are based on the reconfiguration of CPT codes for evaluation and management services with increased payments, but based on time rather than components. The average increase in work RVU values is 8% or 0.17 work RVUs, for new patient codes and 28% or 0.33 work RVUs, for established patient visit codes.

CMS is required to keep the PFS budget neutral, which means that increasing the work RVU values for these 9 codes would require CMS to decrease work RVU values for other CPT codes, reduce the conversion factor, or some combination of both.

CMS announced in the calendar year 2020 Medicare Physician Fee Schedule (PFS) final rule that it would implement changes to office visit Evaluation and Management codes for the 2021 calendar year.

The expected 2021 PFS changes include documentation and code selection updates and updates to work RVU (wRVU) values. This alert will focus on the wRVU value updates that affect code ranges 99201 to 99205 (new patient visit codes) and 99211 to 99215 (established patient visit codes).

Evaluation and Management Services

CMS announced its plan to remove code 99201 from the new patient visit code range increase the wRVU values for the remaining new patient and established patient visit codes as outlined in the tables below:

2021 Physician Proposed Payment Rates for E/M Services








Office/outpatient visit new




New Patient Office Visit




New Patient Office Visit




New Patient Office Visit




New Patient Office Visit




Office/outpatient established patient




Office/outpatient established patient




Office/outpatient established patient




Office/outpatient established patient




Office/outpatient established patient




Phone e/m phys/qhp 5-10 min




Phone e/m phys/qhp 11-20 min




Phone e/m phys/qhp 21-30 min




The average increase in wRVU values is 8 percent, or 0.17 wRVUs, for new patient codes and 28 percent, or 0.33 wRVUs, for established patient visit codes.

CMS is required to keep the PFS budget neutral, which means that increasing the wRVU values for these nine codes would require CMS to decrease wRVU values for other CPT codes, reduce the conversion factor, or some combination of both.

Ambulatory Surgery Center and HOPD Rule – See Comment Letter

CMS has released the 2021 proposed payment rule for ASCs and HOPDs today. Overall, ASCs received inflation update factor of 3% similar to HOPDs, whereas conversion factor remains $48.984 for ASCs compared to $83.697 for HOPD.

Multiple codes have been added; however, none of these are related to interventional pain management.

This rule published provides us with proposed payment rates for 2021 for ASCs, as well as hospitals. We will focus on ASCs as of now, in the future we will publish hospital rates too. As shown in the links below, there have been some increases to majority of the codes.

Some of the codes with major abnormalities are intercostal nerve blocks (first level) and intercostal nerve block add-on codes (the definition was changed last year), but CMS continues to follow the old philosophy. It also raises the doubts: Did CMS ask for the revision of the codes or did someone ask the AMA to change these codes? Consequently, reimbursement levels for these still appear to be inappropriate. Further, reimbursement for genicular nerve blocks and genicular nerve radiofrequency also seem to be still inadequate and inaccurate.

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