2021 MPFS final rule expands telehealth services, finalizes E/M documentation changes

The 2021 Medicare Physician Fee Schedule (MPFS) final rule, released December 2, extends certain telehealth benefits but makes cuts to the Medicare conversion factor (CF) to offset evaluation and management (E/M) changes that would otherwise have resulted in significant reimbursement increases. Most provisions of the final rule are effective January 1, 2021.

CF and E/M

CMS cut the Medicare CF by 10.2%. The reduction is intended to counteract increased fees for E/M office visit codes 99202–99215 due to the agency’s adoption of AMA-approved relative value unites (RVU) for this group of codes. Without the CF reduction, the RVUs for these codes would have been raised by 28%.

However, due to the CF reduction these gains will be largely neutralized and some codes, such as 99202–99204, will see a reduction in reimbursement.

E/M documentation

CMS finalized changes to E/M office visit documentation guidelines for codes 99202–99215. Effective January 1, these codes will be selected based on either time or medical decision-making.

Telehealth

CMS finalized 114 Category 2 codes for telehealth. These codes are cleared for use outside of CMS’ normal restrictive distant-and-originating-site requirements and are eligible for other flexibilities under the public health emergency (PHE). New Category 2 telehealth-eligible codes added in this group include the following:

• 90853 (group psychotherapy)
• 96121 (psychological and neuropsychological testing)
• 99334–99335 (domiciliary, rest home or custodial care services, established patients)
• 99347-99348 (home visits, established patients)
• 99483 (cognitive assessment and care planning services)
• G2211 (visit complexity inherent to certain office/outpatient E/M)
• G2212 (prolonged services)

The agency also created a new Category 3 of codes that will remain on the telehealth list through the calendar year in which the PHE ends, according to the final rule.

However, organizations must be aware that unless Congress changes the law, CMS’ traditional telehealth rules and restrictions eventually will go back into effect.