The Medicare Physician Fee Schedule is the annual regulatory rule released by the Centers for Medicare & Medicaid Services (CMS) that updates the standards for physician reimbursement and policies related to the delivery of health care. While the regulations are for services for Medicare beneficiaries, Medicaid programs and private insurers utilize the regulations as standards for their own payment rates and coverage policies.
This is a summary of the direct impacts for obstetrician-gynecologists’ practices in 2021. For more information, please visit ACOG’s Payment Advocacy and Policy Portal.
Evaluation and Management (E/M) Codes for Office Visits
CMS finalized the adoption and relative-value units (RVUs) for E/M codes for office visits, including 2 add-on codes for single, serious condition or a complex condition (G2211) and time spent above 89 minutes for new patients and 69 minutes for established patients (G2212).
|CPT Code||E/M Level||2021 Non-Facility RVUs|
|99202||New Patient Straightforward||2.14|
|99203||New Patient Low||3.29|
|99204||New Patient Moderate||4.94|
|99205||New Patient High||6.53|
|99211||Established Patient Minimal||0.69|
|99212||Established Patient Straightforward||1.68|
|99213||Established Patient low||2.69|
|99214||Established Patient Moderate||3.81|
|99215||Established Patient High||5.34|
Obstetric & Gynecologic Payment
Medicare reimbursement is calculated using RVUs for each procedure multiplied by a conversion factor, then adjusted for geographic differences. CMS finalized the annual conversion factor at $32.41, significantly lower than the 2020 conversion factor of $36.09. The lowered conversion factor impacts reimbursement rates for Medicare and Medicaid beneficiaries, and may impact private payer rates if they adopt CMS policies. ACOG is working with Congress to change the conversion factor; Take Action and contact your representatives to let them know this cut is unacceptable.
Because of technicalities in federal law, ACOG was able to negotiate increased RVUs for obstetric payments that include E/M visits:
|Code||Description||2020 RVUs||2021 RVUs|
|59400||Routine – vaginal||61.53||72.01|
|59410||Delivery & postpartum||30.29||31.83|
|59515||Cesarean delivery & postpartum||36.89||39.20|
|59614||Vbac & postpartum||33.05||34.43|
|59618||Attempted vbac delivery||69.12||80.41|
|59622||Attempted vbac & postpartum||38.12||40.64|
However, those same technicalities prevented CMS from updating the surgery codes. Below is a sample of gynecology surgery codes with 2020 and 2021 RVUs and the national payment rate. Please note that payment is also adjusted for geographic differences; therefore, these rates do not represent actual rates across the country.
|Code||Description||2020 RVUs||2020 Payment||2021 Facility RVUs (*Non-Facility RVU)||2021 Payment|
|57282||Colpopexy, extra-peritoneal approach||15.18||$547.85||20.87||$676.40|
|57283||Colpopexy, intra-peritoneal approach||20.25||$730.82||21.02||$681.26|
|57520||Conization of cervix||8.33
|58570||Laparoscopy, total hysterectomy||22.99||$829.71||24.11||$781.41|
|58575||Laparoscopy, hysterectomy, resection of malignancy||54.91||$1,981.70||57.31||$1,857.42|
|58600||Ligation of fallopian tubes||10.66||$384.72||11.19||$362.67|
The ACOG 2021 Coding Manual includes RVUs for all of the codes used by obstetrician-gynecologists, as well as coding rules related to procedures billed on the same day. CMS also publishes RVUs and payment rates in their online fee schedule look-up tool.
During the Public Health Emergency (PHE), CMS lifted and added several regulations related to telehealth on a temporary basis. Some regulations are limited by federal law; others will be extended through the PHE and a few were made permanent.
The Medicare list of telehealth services will be updated to include additional services and temporarily extend E/M services used in the inpatient setting and the emergency department through December 31, 2021.
Medicare regulations were updated to remove dated technology from the definition of telecommunications for telehealth; however, CMS also indicated that their interpretation of telecommunication systems “…precludes the use of audio-only technology for purposes of Medicare telehealth services.” Therefore, after the PHE ends, audio-only visits will not be reimbursed for Medicare beneficiaries. For 2021, CMS created HCPCS code G2252 (G2252 (Brief communication technology-based service, e.g. virtual check-in, by a physician or other qualified health care professional who can report evaluation and management services, provided to an established patient, not originating from a related E/M service provided within the previous 7 days nor leading to an E/M service or procedure within the next 24 hours or soonest available appointment; 11-20 minutes of medical discussion). The code is intended to determine if a face-to-face visit is necessary.
In addition, federal law restricts the use of telehealth for Medicare beneficiaries geographically. At the end of the PHE, the geographic constraints of the law will apply. Medicare beneficiaries will only be eligible to receive telehealth services if they reside in a federally-designated rural health professional shortage area or if they are receiving care for substance use disorders.
Reimbursement for Personal Protective Equipment (PPE) Expenses
ACOG, in collaboration with the American Medical Association (AMA), advocated for CMS to add CPT code 99072 (Additional supplies, materials, and clinical staff time over and above those usually included in an office visit or other non-facility service(s), when performed during a Public Health Emergency, as defined by law, due to respiratory-transmitted infectious disease) to the 2021 fee schedule. Instead, CMS bundled the code value into the practice expense of codes they deemed warranted the additional expense. In other words, 99072 cannot be billed separately for Medicare beneficiaries.
On a follow-up call with CMS, officials indicated that this increase in practice expense value to the codes is temporary and may be reassessed after the PHE. ACOG is also aware that several private payers were waiting for the final CMS determination before allowing 99072 to be billed for their patients and has not yet been notified that the code will be accepted.
There are several other provisions in the 2021 rule, including the quality payment program, treatment for substance use disorders and opioid use disorders, and the supervision of students and residents. For questions related to these or other issues, please visit ACOG’s Payment Advocacy and Policy Portal.