CMS 2021 Final Rule: What practices can do


Insights from MGMA’s Medical Practice Excellence Pathways Conference.

At MGMA’s Medical Practice Excellence Pathways Conference, Justin Chamblee, CPA and senior vice president of Coker Group, gave a presentation overviewing CMS’s 2021 Final Rule changes and exploring the impact these changes will have on wRVUs and physician compensation.

According to the presentation, some key changes to the 2021 Office / Outpatient E/M codes include:

  • The elimination of 99201
  • History and exam no longer count toward code level
  • Level of service is based on time OR medical decision making
  • New prolonged care codes specifically for office/outpatient in 15- minute increments
  • New times associated with office E/M codes

Net increases in RVUs means that Medicare payments for E/M visits will increase in 2021, then fall in 2022 compared to 2021 levels, Chamblee said in his presentation. Furthermore, due to budget neutrality requirements, payments for other services will be reduced and, as a result, some specialties will experience reimbursement increases while others experience decreases

Specialties that focus on office visits are expected to experience the most significant positive impact. Specialties that are hospital-based or focus on procedures are expected to experience the most significant negative impact.

The table below lists how Chamblee has calculated each specialty may be effected.

Positively Impacted (+3% or more)

Moderatley Impacted (-2% to +2%)

Negatively Impacted (-3% or more)

  • Family Medicine
  • Nephrology
  • Endocrinology
  • Neurology
  • OB/GYN
  • Pediatrics
  • Urology Psychiatry
  • Otolaryngology
  • Allergy/Immunology
  • Endocrinology
  • Rheumatology
  • Hematology/Oncology
  • Interventional Pain Management
  • NPs/PAs
  • Vascular Surgery
  • Dermatology
  • Podiatry
  • Cardiology
  • Geriatrics
  • Pulmonary Disease
  • Internal Medicine
  • Radiology
  • Anesthesiology (MD/CRNA/AA)
  • General Surgery
  • Orthopedic Surgery
  • Chiropractor
  • Critical Care
  • Emergency Medicine
  • Pathology
  • Thoracic Surgery
  • General Surgery
  • Colon/Rectal Surgery
  • Infectious Disease
  • Neurosurgery
  • Plastic Surgery
  • Gastroenterology
  • Orthopedic Surgery
  • Physical Medicine
  • Radiation Oncology

Below are some tips from the presentation regarding what practices should do to prepare for these changes.

When reviewing RVUs and collections to understand the impact of the 2021/2022 MFPS changes, Chamblee says practices should review:

  • Current production (wRVUs and professional collections)
  • Analyze the impact of the 2021 and anticipated 2022 MPFS changes using 2020 productivity
  • Compare 2020 to the estimated 2021 and 2022 results
  • Identify where changes can be made (generally TCC per wRVU) to mitigate the impact to physician compensation