CMS Finalizes Changes for 2020 Medicare Physician Fee Schedule

Last Updated: Nov 7, 2019

MedicareThe final 2020 Medicare Physician Fee Schedule (MPFS) includes changes to the planned overhaul of payment for Evaluation and Management (E/M) services that was introduced in the 2019 MPFS. The Centers for Medicare and Medicaid Services (CMS) announced the final rule on Nov. 1, 2019.

Here’s a look at highlights of the final rule:

  • Documentation Changes for Verification of Medical Records – In an effort to reduce administrative burden, CMS will allow physicians, physician assistants, nurse practitioners, clinical nurse specialists, and certified nurse-midwives to review and verify (rather than re-document) notes made in the medical record by other members of the medical team in 2020.

  • Transitional Care Management (TCM) & Chronic Care Management (CCM) – The 2020 MPFS includes an increase in payment for TCM. It also creates a Medicare-specific code for additional time spent beyond the initial 20 minutes allowed in the current coding for CCM services.

  • Principal Care Management Services (PCM) – CMS is creating new coding in 2020 for PCM which will pay clinicians for providing care management services for beneficiaries with a single serious, high risk condition. PCM services would be used when the serious condition is expected to last between three months and a year or until death. The patient could receive PCM services from more than one clinician.

  • Opioid Use Disorder (OUD) Treatment – CMS has finalized several changes related to opioid and substance use disorder (SUD) treatment in its 2020 MPFS; here are a few of the changes:

    • Adding the following codes to the list of telehealth services: HCPCS codes G2086, G2087, and G2088, which describe a monthly bundled episode of care for treatment for opioid use disorders; treatment to include care coordination, individual therapy, and group therapy and counseling.

    • Finalizing a policy to allow counseling and therapy services described in the bundled payments to be provided via two-way interactive audio-visual communication technology as clinically appropriate. 

  • Merit-based Incentive Payment System (MIPS) Changes for 2020

    • CMS is increasing the performance threshold to 45 points during the 2020 performance year (an increase of 15 points on the 30-point threshold for 2019).

    • The additional performance threshold for exceptional performance will increase to 85 points, an increase of 10 points compared to 2019.

    • For 2020, CMS finalized the following performance category weights:
      • Quality performance category is weighted at 45% (no change from PY 2019);
      • Cost performance category is weighted at 15% (no change from PY 2019);
      • Promoting Interoperability performance category is weighted at 25% (no change from PY 2019); and
      • Improvement Activities performance category is weighted at 15% (no change from PY 2019).
    • CMS finalized increasing the participation threshold in the Improvement Activities Performance Category from a single clinician to 50 percent of the clinicians in the group or virtual group practice. The finalized policy differs from the proposal in that it permits the clinicians to perform the activity during any continuous 90-day period during the performance year (i.e., everyone does not need to perform the activity at the same time).
    • MIPS Structural Changes Finalized for the 2021 Performance Year – A new framework for MIPS in 2021 – which CMS has termed MIPS Value Pathways (MVP) – aims to significantly reduce the number of measures on which physicians and other clinicians are required to report. CMS says that, under the new framework, clinicians will report on a smaller set of measures that are specialty-specific and more relevant to the specialty’s scope of practice. The goal of these changes is to improve value, reduce burden, and remove barriers to APM participation. The new framework will be developed in collaboration with stakeholder input over the coming months. 

  • 2020 MPFS Conversion Factor – The conversion factor is slightly greater than last year’s amount. CMS finalized a conversion factor of $36.09 for 2020, compared to the 2019 factor of $36.04.

Additional Resources

CMS offers fact sheets on the final rule:

PAMED members with questions can also contact our Knowledge Center at 855-PAMED4U (855-726-3348) or

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