CMS 2021 Final Rule: What practices can do

Chamblee says that practices should be slow to make changes until they understand the impact such changes could have on the overall organization.

“Really do a good bit of financial analysis, understand the impact on worker use on collections, not only for 2021…” he says.

Practices should also consider conducting an impact assessment on how the 2021 MPFS changes will affect wRVUs and total revenue, while also reviewing the total economic impact (subtract total physician compensation change from total revenue change), and then determine the appropriate course of action that best fits the organization’s needs.

If possible, the 2020 fee schedule can mitigate the impact of lower reimbursement conversation factor on the overall bottom line while more diligence is completed, Chamblee says.

“This is not a long-term solution. This is more so to provide breathing room to figure out what a long-term solution may be,” he says.

Due to the changes that we have seen here, and the fact that many organizations feel hamstrung contractually by the language in their contracts, we've [suggested]… maybe provide a more generic statement that says that we will base our work over us initially on the 2020 fee schedule, but then future adjustments to that will be subject to the discretion of the medical group or the health system,” Chamblee says.

Practices should review contracts and ensure you are not locked into using a specific fee schedule. Ideal language would give the medical group the discretion to decide on which fee schedule to use.

Camblee provided examples of language that locks you in, versus language that allows flexibility.

Language that locks you in: “wRVUs will be based on the schedule published by the Center’s for Medicare and Medicaid Services (CMS) that is in place on the applicable date of service”

Language that allows flexibility: “wRVUs will initially be based on the 2020 schedule published by the Centers for Medicare and Medicaid Services (CMS), and, subject to the discretion of [Medical Group], may be adjusted each [insert date] during the term of this Agreement to be based on the immediately preceding year’s schedule published by CMS”