Last week, CMS finalized the Physician Fee Schedule (PFS) for next year. The 2021 PFS brings in sweeping changes that embrace technology and increase flexibility for physicians, with some of these changes being applicable to FQHCs.
“The calendar year (CY) 2021 PFS final rule is one of several rules that reflect a broader Administration-wide strategy to create a healthcare system that results in better accessibility, quality, affordability, empowerment, and innovation,” a CMS press release about the new finalizations stated.¹
Here are a few notable changes FQHCs should note and health center patients could benefit from in the new year as the health industry embraces change:
Principal Care Management
In 2021, FQHCs and RHCs will now be able to bill for Principal Care Management (PCM) services. CMS finalized the service as a separate payment for the upcoming year. For any PCM services provided on or after January 1 of this year, clinicians can bill HCPCS codes G2064 and G2065, which fall under the general care management service code G0511. FQHCs and RHCs will be able to bill the service separately or together with other eligible claims.
These two codes above will be added to CPT codes 99484, 99487, 99490 to calculate a new national non-facility PFS rate for code G0511. This average will be updated annually.¹
FQHC Market Base
The FQHC market base is being revised in 2021 to reflect a 2017 base year, in which the FQHC payment update will be at 1.7 percent.¹
Preparing for a Telehealth-Heavy Focus
Technology is becoming increasingly integrated into clinician workflow and capabilities. CMS is embracing this change, and as a part of this year’s changes, allowed more telehealth flexibility. Details on those changes follow in the subsections below.
“…The pandemic accentuated just how transformative [telehealth] could be, and several months in, it’s clear that the healthcare system has adapted seamlessly to a historic telehealth expansion that inaugurates a new era in healthcare delivery,” said HHS secretary Alex Azar in a second press release relating to expanded telehealth coverage from CMS.²
Many of the new permanent telehealth codes added are only eligible for RHC use. CMS says it does not have the “statutory authority” to allow permanent relaxations for FQHCs. However, the historic telehealth expansion for RHCs this year, is a step in the right direction, CMS continued to state in the same press release.²
Concerning preparation for 2021, this Foley article on recent PFS changes says that providers should be both ready to quickly embrace these new changes, as well as be ready to adapt in the case of a rollback on temporary relaxations.
“Continued expansions in Medicare reimbursement mean providers should make enhancements to telehealth programs now, both for the immediate cost savings and growing opportunities for revenue generation, to say nothing of clinical quality and patient satisfaction,” the authors in the Foley article said. “However, providers should be mindful of any sunset provisions on these expansions and be prepared to adjust operations in accordance with those timelines.”
Telehealth changes that may be applicable are as follows:
CMS finalized a few items, as well as provided clarification for others.¹
- Finalized: Consent to receive RPM services may be obtained at the same time as the services are being furnished.
- Finalized: Auxiliary personnel, including contracted employees, may provide services that fall under CPT codes 99453 and 99454
- Clarified: Data collected during RPM services must be transmitted electronically, rather than self-reported.
- Clarified: To meet the requirements of the CPT codes, data must be collected at least 16 days of every 30
- Clarified: In the 20 minutes, as required by CPT codes 99457 and 99458, physicians can also furnish care management services conjointly.
Note for FQHCs and RHCs: “Carrie Nixon, co-founder and managing partner of the Nixon Gwilt law firm, faulted CMS for failing to extend stand-alone reimbursement [for RPM] for federally qualified health centers (FQHCs) and rural health clinics (RHCs), two locations that have seen a lot of telehealth use during the pandemic.” – Source
In an effort to decrease patient/provider exposure during the COVID-19 pandemic, physicians are now allowed to provide direct supervision virtually through December 31, 2021 or until the end of the Public Health Emergency, whichever comes last. However, note that direct supervision is not allowable in cases where the physician is using audio-only equipment. The service must use interactive video and audio technology. A user-friendly platform like Certintell’s ensures quality visits, while also keeping you in compliance with HIPAA.¹
Opioid Use Disorder:
- CMS finalized that OUD services can implement opioid antagonist medications, such as naloxone.
- The agency is now requiring that Initial Preventive Physical Examinations (IPPE) and Annual Wellness Visits (AWVs) be a routine part of opioid treatment services. The purpose of the two will be to screen for Substance Use Disorders and review any prescriptions so appropriate follow-up and referral can be provided for high-risk patients.
- CMS finalized that periodic assessments can be furnished via two-way, interactive audio-video technology¹
How We Can Help: Recurring preventative care services such as AWVs are extremely helpful in preventative care, but sometimes physicians may lack the time to thoroughly perform them with patients. Certintell can work as an extension of your health center to help complete AWVs, leaving clinicians time to continue building and executing patient-centered care plans that go beyond these routine preventive care services.
UPDATED: January 6, 2021
¹ “Final Policy, Payment, and Quality Provisions Changes to the Medicare Physician Fee Schedule for Calendar Year 2021 | CMS.” Center for Medicare and Medicaid Services, 1 Dec. 2020, www.cms.gov/newsroom/fact-sheets/final-policy-payment-and-quality-provisions-changes-medicare-physician-fee-schedule-calendar-year-1.
² “Trump Administration Finalizes Permanent Expansion of Medicare Telehealth Services and Improved Payment for Time Doctors Spend with Patients | CMS.” Center for Medicare and Medicaid Services, 1 Dec. 2020, www.cms.gov/newsroom/press-releases/trump-administration-finalizes-permanent-expansion-medicare-telehealth-services-and-improved-payment.
³ “Top Five New Telehealth Policies in Medicare 2021 in Physician Fee Schedule.” Blogs | Health Care Law Today | Foley & Lardner LLP, 2 Dec. 2020, www.foley.com/en/insights/publications/2020/12/top-five-new-telehealth-policies-in-medicare-2021.