When the proposed Medicare Physician Fee Schedule came out last year, it really got everyone worried. In a time where we are all facing issues related to COVID, this seemed like a really big problem. Professional organizations lobbied and everyone tried to stop the proposed changes, and the 10.2% decrease didn’t happen, but other changes will still be taking place. So how bad is it really and how will it affect your organization? Well, it all depends on your payer mix and the services performed in your practice. Now is the time to sit down with a spreadsheet, look at the numbers and assess the real potential impact - it might not be as bad as you thought.

Here’s the good and bad news. The Consolidated Appropriations Act of 2021 modified the 2021 Medicare Physician Fee Schedule (MPFS) as follows:

• Included a 3.75% increase in MPFS payments for 2021: Reimbursement for some services went up and some went down.The 3.75% is just the overall increase, which isn’t really a whole lot, but it’s better than what was going to happen.
• Suspended the 2% payment adjustment (sequestration) through March 31, 2021: We hope that this will be held off again, but it is dependent on legislation.
• Reinstated the 1.0 floor on the work Geographic Practice Cost Index through 2023
• Delayed implementation of the inherent complexity add-on code for evaluation and management services (G2211) until 2024: We recently published an article about this code and its potential to increase revenue, but that is on hold now.

To reflect these changes, CMS has recalculated the payment rates and conversion factor (CF) for 2021.The revised MPFS conversion factor for 2021 is 34.8931 instead of the final rule CF of 32.4085 which is less than that original 10.2% decrease but still a decrease of 3.3% (down from 36.0896). So there will still be a pay cut, but not quite as much as it was going to be. There is also some good news when it comes to RVUs for CMT and E/M, and some bad news for physical medicine.

2021 Reimbursement CMT Services

Fortunately, the RVUs for the main CMT services (98940-98942) increased by 0.01 due to an increase in the practice expense even though code 98943 remained the same. Looking at the Medicare reimbursement for 98942 (using the national unadjusted allowed amount) is down $1.09 from $54.13 in 2020 to $53.04 in 2021. Although that dollar change does add up over the course of the year, particularly for those practices that mainly treat Medicare patients, that small bump in the RVU might translate to small increases for other payers who have not made as much of a cut to their own internal conversion factors as Medicare.

E/M Services Reimbursement

Even though Medicare does not allow doctors of chiropractic to bill for E/M services, the good news is that the changes to time frames, guidelines, and RVUs have the potential to increase revenue when billing other payers. Changes to time frames and guidelines are not discussed here. See the ChiroCode DeskBook or innoviHealth’s Comprehensive Guide to Evaluation & Management (both are available in the online store) for more information.

Without going into details, since selection of the level of service for codes 99202-99215 are based on either time or medical decision making, some doctors have discovered that they actually qualify for higher levels of service. Add to that the fact that reimbursement for E/M visits (except 99202 and 99211) have gone up, it stands to reason that E/M reimbursement by other payers has the potential to offset losses due to Medicare cuts in CMT services. The following table shows reimbursement amounts for the most commonly reported E/M services for 2020 and 2021:

Year	99202	99203	99204	99212	99213	99214
2021	$73.97	$113.75	$169.93	$56.88	$92.47	$131.20
2020	$77.23	$109.35	$167.09	$46.19	$76.15	$110.43

Reimbursement for Physical Medicine Services

To review the impact on physical medicine services, we looked at the following most common codes for chiropractic: 97012, 97014, 97035, 97110, 97124, 97140. Now even though these are not billable to Medicare, other payers adopt RVUs so there is value in knowing Medicare reimbursement. Interestingly, some RVUs went up, others went down, and some stayed the same. The following table shows RVUs for these codes for 2020 and 2021:

Year	97012	97014	97035	97110	97124	97140
2021	0.43	0.39	0.42	0.87	0.85	0.80
2020	0.43	0.41	0.41	0.87	0.83	0.80

Summary

January is a great time to review your fee schedule and this year it becomes even more important to review your fees and evaluate payer-contracted amounts. Look at your top billed codes overall and by payer. Plug in the numbers and see how these changes may affect your bottom line. Don’t forget that FindACode.com includes comprehensive fee information including zip code specific information, workers compensation fees, and UCR fees (available by subscription) for those that wish to do a more comprehensive review.