CMS Releases Draft 2020 Part B Fee Schedule

Chris Pittman, MD, FAVLS, FACR

On July 29, 2019, the Centers for Medicare & Medicaid Services (CMS) issued a proposed rule that includes proposals to update payment policies, payment rates, and quality provisions for services furnished under the Medicare Physician Fee Schedule (PFS) on or after January 1, 2020. The AVLS Healthcare Advocacy Committee has commenced a detailed review of the proposed 2020 Physician Fee Schedule. CMS released this draft regulation on July 29th. Comments are due to CMS by September 27th and AVLS will be submitting detailed comments.  We are also discussing our Federal advocacy options with other stakeholders

• CMS is affirming the RUC recommendations from the April 2018 RUC meeting for physician work RVUs and Practice Expense for stab phlebectomy procedures, codes 37765(10-20 incisions), and 37766(>20 incisions). While the precise payment impact is subject to geographic variation, as well as Part B updates that will be reflected in the Final Rule in November, the Total Non-Facility RVUs will fall sharply.  In the proposed Rule, 37765 falls 31.49 % compared to 2019, and 37766 drops 32.6 %.  AVLS is concerned that such a steep drop might create patient access issues and create unintended site of service migration.
• AVLS remains concerned that the phased-in pricing of key supplies and equipment used in Non-Facility Practice Expense may not reflect pricing that is available to a typical practice. The Advocacy Committee is reviewing many of these venous supply inputs for possible discrepancy. These phased-in supply costs will impact payment for thermal ablation codes, and possibly other vein codes.
• CMS is proposing greater flexibility in how Physician Assistants may practice and supervision requirements of PAs.
• The Conversion Factor for 2020 is forecasted at $36.09, a very slight increase over 2019.
• A new MIPS Value Pathway is designed to give greater reporting flexibility under the MIPS program.

We value your input on all Advocacy matters and encourage any of our members to reach out.  Our AVLS Healthcare Policy Chair is Dr. Stephen Daugherty, at [email protected]. The Chair of the Healthcare Advocacy Committee is Dr. Chris Pittman, at [email protected]. On the AVLS staff, Robert White serves as Director, Health Care Policy & Advocacy. Robert’s email is [email protected], and his phone is 510-346-6800

With Best Regards,

Chris Pittman, MD, FAVLS, FACR