Enacted on December 27, the Consolidated Appropriations Act, 2021 (CAA) is one of the largest bills ever passed by Congress—both in terms of funding and policy changes. While there are numerous modifications impacting family medicine physicians, we are focusing on those impacting the Medicare Physician Fee Schedule (PFS).

Key Adjustments

The CAA made the following significant modifications to the PFS:

  • Extend the moratorium of Medicare sequestration through 3/31/2021 (averts a 2% reduction in Medicare provider payments that would have commenced on 1/1/2021)
  • Increase the PFS Conversion Factor (CF) by 3.75% for 2021
  • Restore the 1.0 floor on the work Geographic Practice Cost Index (GPCI) through 2023
  • Delay implementation of the inherent complexity add-on code for evaluation and management (E/M) services (G2211) until 2024

According to the Centers for Medicare & Medicaid Services (CMS), these adjustments result in a revised CF of 34.8931. CMS previously finalized a CF of 32.4085 for 2021, meaning the CF is increasing by 7.667% compared to what was originally finalized.

The many policy changes CMS finalized, including updated relative value units (RVUs) for office/outpatient E/M visits (CPT codes 99202–99205 for new patients and CPT codes 99211–99215 for established patients), as well as the new framework for E/M level selection, remain in place and are not impacted by the changes made by the CAA.

Implications for Family Physician Reimbursements

Due to the mechanics of the PFS, RVUs will decrease for many codes and increase for others. For the office/outpatient E/M visits, the table below (also available here for download) illustrates how the RVUs are changing from what CMS originally finalized (marked by strikethrough) and shows the RVUs that incorporate the CAA change (marked by underline). However, in all cases, the actual reimbursement for each code is increasing—compared to what was originally finalized—due to the CF increase.

Outlook

While the overall reimbursement has increased for these E/M visit codes, the loss of the G2211 add-on code means family medicine physicians are unable to bill and receive the estimated $15.88 in reimbursement that the G2211 code would have provided. In addition, the return of the Medicare sequestration 2% reduction on April 1, 2021, and expiration of the 3.75% PFS increase on January 1, 2022, will most likely decrease family physician reimbursement.

Similarly, the removal of the GPCI work floor in 2024 will impact the PFS reimbursement—all of which may be offset should the G2211 add-on code be reimplemented at that time. In addition, there may be more changes to the PFS, E/M services and others that could further impact family medicine physician reimbursement in future years.

As Congress considered making legislative changes to CMS’s originally finalized PFS rule, ACOFP was proactively involved with key Committees of Jurisdiction in both the House of Representatives and the Senate. Discussions took place to ensure that the final legislation did not adversely impact family physicians’ reimbursements, in comparison to the original final rule. While ACOFP also actively participated in the coalition effort that extended the Medicare sequestration moratorium, more work remains to prevent the Medicare sequestration adjustment from being implemented on April 1, 2021.

ACOFP continues to assess the impact of these funding and policy changes on family medicine physicians and seeks opportunities to further enhance reimbursement for ACOFP members.

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