ACR Responds to CY2021 Medicare Physician Fee Schedule

October 5, 2020 | Advocacy


The rheumatology community applauds E/M coding changes, expansion of telehealth services and adoption of the GPCX1 single complexity add-on code

ATLANTA – In comments submitted to the Centers for Medicare and Medicaid Services (CMS), the American College of Rheumatology (ACR) applauded the agency for continuing to recognize the value of rheumatology, and other cognitive care specialties, by affirming changes to Evaluation and Management (E/M) reimbursement to better reflect the work and expertise needed to treat complex patient populations. In addition, the ACR commended CMS for permanently expanding certain telehealth provisions and establishing a single complexity add-on code.

“At a time when specialty providers are facing unprecedented challenges and resource constraints as a result of the COVID-19 pandemic, we appreciate CMS’ continued efforts to implement policies and reforms that will help the rheumatology community navigate these challenges and continue to provide quality care for patients with complex conditions,” said Ellen Gravallese, MD, President of the ACR. “The agency’s continued recognition of the value of E/M services – which have been historically undervalued by Medicare – is a win for the millions of Medicare beneficiaries living with a rheumatic disease and will ensure they can continue to receive the specialty care they need to manage their disease.”

Noting that the COVID-19 public health emergency has precipitated a rapid adoption of telehealth services by many specialties – and that such changes will eventually call for more permanent regulatory flexibility – the ACR expressed concern that current coding, coverage, and payment rates for audio-only telephone E/M services will not continue after the public health emergency is rescinded. The ACR also urged CMS to improve coding and billing guidelines to reflect the administrative complexity of delivering care via telehealth and encouraged the agency to allow direct supervision to be provided to members of the care team using real-time, interactive audio/video and audio-only technology in order to maximize the amount of time focused on delivering patient care. In addition, the ACR expressed support for the extension of telehealth reimbursement for physical and occupational therapy and welcomes the opportunity to work with CMS to demonstrate how telehealth can be effectively used to provide the quality of care necessary for patients living with musculoskeletal and rheumatic diseases.

Lastly, the ACR expressed strong support for the adoption of GPCX1, the single complexity add-on code, that will be available to all specialties for visits that are part of ongoing care related to a patient’s single, serious, or complex chronic condition. However, the rheumatology community disagreed with CMS’ utilization assumption – which impacts reimbursement and evaluation criteria – and urged the agency to move forward with a more reasonable figure in addition to implementing a series of other technical changes to the code.

“The ACR remains committed to partnering with CMS to ensure rheumatology providers can continue delivering the high-quality care our Medicare patients need and deserve,” Dr. Gravallese concluded. “During these unpreceded times, it is imperative that providers are supported via appropriate reimbursement, embracing telehealth, alleviating administrative burden and streamlining programs designed to advance quality care. We look forward to working with CMS as it continues its efforts to realize these goals.”


Media Contact
Monica McDonald


About the American College of Rheumatology
Founded in 1934, the American College of Rheumatology (ACR) is a not-for-profit, professional association committed to advancing the specialty of rheumatology that serves nearly 8,500 physicians, health professionals, and scientists worldwide. In doing so, the ACR offers education, research, advocacy and practice management support to help its members continue their innovative work and provide quality patient care. Rheumatology professionals are experts in the diagnosis, management and treatment of more than 100 different types of arthritis and rheumatic diseases.

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