CMS Releases 2021 MPFS Proposed Rule

August 4, 2020

On Monday, August 3, the Centers for Medicare and Medicaid Services (CMS) released the calendar year 2021 Medicare Physician Fee Schedule (MPFS) proposed rule. In this rule, CMS proposed changes to the payment provisions, introduced new coding structure for the evaluation and management (E/M) codes and updated the Quality Payment Program.

The adoption of the new E/M coding structure recommended by the American Medical Association (AMA) will result in significant payment reductions to nuclear medicine and radiology services unless the government removes the budget neutrality requirements. The society will continue to work with pertinent stakeholders to minimize the impact of these proposed payment reductions.

CMS is also proposing removal of the national coverage determination (NCD) for non-coverage of infection/inflammation, along with 8 other NCDs. The society is pleased with the proposed expansion of non-oncologic PET coverage, as the society’s leadership, staff and consultants held multiple in-person meetings and conference calls with the Coverage and Analysis Group at CMS to remove this NCD. Although our ultimate goal is to get CMS coverage for all the approved PET indications, this is a pivotal first step.

CMS did not provide additional guidance on the implementation of the appropriate use criteria (AUC) program in this rule. Currently, CMS is accepting data under the educational and operations testing period until December 31, 2020, and the program will be fully implemented beginning January 1, 2021. The society will seek further guidance from CMS regarding the payment denial for non-AUC consultation and next steps for the implementation of this program.

SNMMI staff is currently reviewing the MPFS rule and will submit a comprehensive comment letter to CMS in the coming weeks. The CY 2021 proposed Medicare physician fee schedule chart may be found here.