AAPM&R Submits Comment Letter for 2021 Medicare Physician Fee Schedule Proposed Rule

Members & Publications


October 5, 2020

In October 2020, AAPM&R submitted a comment letter to the Centers for Medicare and Medicaid Services (CMS) regarding the 2021 Medicare Physician Fee Schedule (MPFS) Proposed Rule, which describes proposed payment and policy changes for next year.

Here are some key points in the proposed rule that might affect physiatrists, which were addressed in our comment letter:

  • A proposed 10.6% cut to the conversion factor (proposed decrease from $36.09 to $32.26). The conversion factor helps determine payment for all services in the fee schedule. CMS is proposing a statutorily required across-the-board cut, which will impact all of medicine, not just physiatry. AAPM&R is strongly advocating against this proposal.
  • Proposed expansion of telehealth services.
  • Expansion of scope of practice flexibilities established under the Public Health Emergency.
  • Implementation of updates to coding and documentation requirements for office and outpatient evaluation and management codes.
  • Proposed updates to the Quality Payment Program for 2021.

CMS estimates that the proposals in this rule, if implemented, would result in a 3% cut to payment for Physical Medicine and Rehabilitation. Because of the variability across our membership, we expect the exact impact on individual practices may vary substantially.

The final rule is expected in early December. Your Academy will continue to monitor these issues and will distribute updates when available.

Visit the Reimbursement Advocacy section of our website for additional details on the 2021 MPFS Proposed Rule.

Legislation Introduced to Alleviate Impact of Conversion Factor Cut for 2021

Nov 09, 2020

Last month, two bills were introduced in the House proposing solutions to the estimated 10.6% Physician Fee Schedule conversion factor cut expected to go into effect January 1, 2021.  The bills offer some relief to the cut, but do not reflect a comprehensive or long-term solution.  AAPM&R has therefore chosen to remain neutral regarding these bills. 

Your Academy continues to advocate for a permanent solution to the conversion factor cut while maintaining the important payment increases to office and outpatient evaluation and management services.