APMA News - January/February 2020 - 42

Reimbursement
By Jeffrey D. Lehrman, DPM

Medicare Changes for 2020
In the summer of 2019, CMS released the 2020 Medicare
Physician Fee Schedule Proposed Rule, which detailed proposed changes for 2020. The proposed rule was subject to a
60-day comment period. These 60 days were among the busiest days of the year for your APMA Health Policy staff, leaders, and committees. During this time, APMA leaders reviewed
the 1,700-page document on the proposed rule, worked with
consultants and other clinical organizations, and ultimately submitted robust comment letters that advocated for the interests
of podiatrists and their patients.
APMA sent the first letter on September 10 with its highest-priority concerns and followed up with a second letter on
September 27. Other stakeholders also submitted comment letters. CMS reviewed them and released the 2020 Medicare Physician Fee Schedule Final Rule in November 2019. Multiple elements of the 2020 final rule are pertinent to podiatrists
and are detailed in this article. Review APMA's comments at
www.apma.org/CommentLetters.

E/M Changes
CMS cancelled its plan to consolidate payments for multiple
Evaluation and Management (E/M) levels. Instead, effective
January 1, 2021, CMS is adopting the new framework for CPT
99201-99215, which had been issued previously by AMA CPT.
CPT 99201 will be deleted. The selection of the level of these
office/outpatient E/M services will be based on either the level of
medical decision making only or total time only. Furthermore,
the means by which the level of medical decision making is
determined is being overhauled. This change will have a significant impact on most podiatrists because the barriers that make
it challenging for most providers who specialize in one area of
the body to reach higher-level E/Ms are being removed. It is essential that all providers start to familiarize themselves with
these changes now so they are ready when 2021 begins. A
webinar that explains these changes can be found at www.apma.
org/Coding.
Effective January 1, 2021, CMS is increasing the relative value units (RVU) for most of the office/outpatient E/M CPT codes.
The current and future RVUs are listed in the table at right.

Principal Care Management
CMS established a new HCPCS code, G2065, which some
podiatrists may find useful in their practices.
G2065-Comprehensive care management services for a
42 APMA News January/February 2020

single high-risk disease, e.g., Principal Care Management, at
least 30 minutes of clinical staff time directed by a physician or
other qualified health-care professional, per calendar month,
with the following elements: one complex chronic condition
lasting at least three months, which is the focus of the care plan;
the condition is of sufficient severity to place patient at risk of
hospitalization or have been cause of a recent hospitalization;
the condition requires development or revision of a disease-specific care plan; the condition requires frequent adjustments in
the medication regimen; and/or the management of the condition is unusually complex due to comorbidities.
Multiple criteria must be met before using this code, and
members are encouraged to read these requirements, found in
Table 24 of the 2020 Medicare Physician Fee Schedule Final
Rule, before considering use of this code.

Consent for Technology-Based Services
CMS finalized the guideline that only a single consent need
be obtained for all communication technology-based services

Code

Current RVU

RVU
Beginning 2021

CPT 99201

.48

Deleted

CPT 99202

.93

CPT 99203

1.42

1.6

CPT 99204

2.43

2.6

CPT 99205

3.17

3.5

CPT 99211

.18

CPT 99212

.48

CPT 99213

.97

1.3

CPT 99214

1.5

1.92

CPT 99215

2.11

2.8

http://www.apma.org/CommentLetters http://www.apma.org/Coding http://www.apma.org/Coding

APMA News - January/February 2020

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