CMS Releases CY 2020 PFS Proposed Rule

On July 29, 2019, the Centers for Medicare and Medicaid Services (CMS) released the CY 2020 Revisions to Payment Policies under the Physician Fee Schedule (PFS) and Other Changes to Part B Payment Policies (CMS-1715-P), which includes proposals related to Medicare physician payment and the Quality Payment Program (QPP). The proposed regulations will be published in the Federal Register on August 14, 2019. Comments are due September 27, 2019.

  • The proposed regulations are available here
  • The fact sheet is available here
  • The QPP factsheet is available here

Some key highlights from the proposed rule follow.

2020 Physician Conversion Factor Remains Flat

The 2020 proposed physician conversion factor is $36.0896. This represents an increase of just 5 cents from the 2019 conversion factor of $36.0391. The proposed anesthesia conversion factor is $22.2774, in comparison to the 2019 conversion factor of $22.2730.

CMS Proposes to Increase Payment for E/M Visits

In this rule, CMS is proposing to accept E/M coding changes adopted by the CPT Editorial Panel and accept a number of payment recommendations made by the American Medical Association (AMA)/Specialty Society RVS Update Committee (RUC) for the office/outpatient E/M visit codes to be effective in CY 2021 and the new add-on CPT code for prolonged services. The AMA RUC-recommended values would increase payment for office/outpatient E/M visits.

CMS Solicits Comments on Ideas for Bundled Payments

While historically CMS has made separate payments for each service provided under the PFS, in recent years CMS has developed bundled payment approaches for the PFS and other Medicare payment systems. Many of these models have been implemented under the authority of the Center for Medicare and Medicaid Innovation. CMS is soliciting comments on opportunities to expand the concept of bundling to improve payment for services under the PFS. While by statute CMS is required to pay for services based on the resources required, they believe there is flexibility within the PFS to become more efficient.

CMS Proposes MIPS Value Pathways

CMS is proposing a new way for clinicians to participate in the Merit-based Incentive Payment System (MIPS). Beginning in the 2021 performance period, this new framework called the MIPS Value Pathways reports on a smaller set of measures that are specialty-specific, outcome-based and more closely aligned to Alternative Payment Models, instead of reporting on many measures across the multiple performance categories of Quality, Cost, Promoting Interoperability and Improvement Activities.

McDermottPlus will be issuing a more detailed summary of the proposed rule shortly.


For more information visit the McDermottPlus Payment Innovation Resource Center or contact Sheila Madhani at 202-204-1459/ or Mara McDermott at 202-204-1462/

Join McDermott+Consulting on August 8, 2019, as we review major highlights from the 2020 Proposed Medicare Physician Fee Schedule and Hospital Outpatient Prospective Payment System proposed rules.