On November 1st, the Centers for Medicare & Medicaid Services (CMS) issued its final policies for the 2020 performance year of the Quality Payment Program (QPP) via the Medicare Physician Fee Schedule (PFS) Final Rule.

The 2020 performance year will maintain many of the requirements from the 2019 performance year, while providing some needed updates to both the Merit-based Incentive Payment System (MIPS) and Advanced Alternative Payment Models (APMs) tracks to continue reducing burden, respond to clinician and stakeholder feedback, and align with statutory requirements. Additionally, CMS is finalizing its MIPS Value Pathways participation framework that beings in the 2021 year.

So what does this mean for you and your practice as you head into 2020?

The final rule, which is mostly unchanged from the proposed rule put forward in July, cuts payments to physical therapists by 8% in 2021.

The 2020 therapy threshold dollar amount for physical therapy and speech-language pathology services combined is $2,080 and is a separate $2,080 for occupational therapy services. This is an increase of $40 from the 2019 threshold.

CMS estimates the 2020 conversion factor to be 36.0896. This is a 0.14% increase from the 2019 conversion factor.

One big win from the original proposed rule was that CMS revised the PTA/OTA modifier requirement. Under the final rule, it will allow separate reporting, on two different claim lines, of the number of 15-minute units of a code to which the therapy assistant modifiers do not apply, and the number of 15-minute units of a code to which the therapy assistant modifiers do apply. When the PT is involved for the entire duration of the service and the PTA provides skilled therapy alongside the PT, the CQ modifier isn't required.

Beginning with dates of service on and after January 1, 2020, the discipline specific therapy modifiers (GO for OT and GP for PT) are still required to be appended to every CPT code billed to the Medicare program. The new PTA and OTA modifiers will be required in addition to the GO and GP modifiers.

MIPS is still expanding with new added measures for: diabetic foot and ankle care; peripheral neuropathy: neurological evaluation and prevention evaluation of footwear; screening for clinical depression and follow-up plan; falls screening and plan of care, elder maltreatment screen and follow-up plan; preventive care and screening: tobacco use: screening and cessation intervention; dementia: cognitive assessment, functional status assessment, and education and support of caregivers for patients with dementia; falls: screening for future fall risk; and functional status change for patients with neck impairment. The rule also removes 2 measures: pain assessment and follow-up, and functional status change for patients with general orthopedic impairments.

These are only a few of the updates included in the 2020 final rule. Other updates include new dry needling codes, updates to biofeedback, negative wound pressure coding values, and much more. Contact hello@lincolnrs.com to learn more about how the final rule updates will impact your clinicians and bottom line in the new year.

To learn more about the PFS Final Rule and the 2020 Quality Payment Program finalized policies, review the following resources directly from CMS:

  • Executive Summary – provides a high-level summary of the 2020 QPP final rule policies

  • Fact Sheet – offers an overview of the QPP policies for 2020 and compares these policies to the 2019 requirements

  • Frequently Asked Questions (FAQs) – addresses frequently asked questions about 2020 QPP final rule policies

  • MVPs Video – provides an overview of the MVPs participation framework