ACP Says 2021 Medicare Physician Fee Schedule and QPP Rule Makes Positive Steps, Improvements Still Needed

Washington, DC (Dec. 9, 2020) —While the 2021 Medicare Physician Fee Schedule (MPFS) makes historic enhancements to payments to physicians for evaluation and management (E/M) services, the American College of Physicians (ACP) says there are still improvements that the Centers for Medicare & Medicaid Services (CMS) should make to help patients and physicians, especially in light of the COVID-19 pandemic.

After the final rule was released, ACP issued a statement praising the historic increases in physician payments for E/M services. That statement also noted that ACP strongly supports the planned implementation of a new code that will allow physicians to better account for complex patient visits. While these are both promising developments ACP is calling for several additional improvements that were not included in the 2021 rule.

“Physician practices, especially small and primary care practices, are dealing with major ramifications due to the COVID-19 pandemic,” said Jacqueline W. Fincher, MD, MACP, president, ACP.  “I fear we may see a multitude of offices being forced to shut their doors over the next year, leaving their patient populations without care. There are additional measures that CMS can and should take to help mitigate this issue and preserve patients’ access to care.”

Among areas where ACP had concerns:

  • While CMS extended payment for audio-only services beyond the end of the public health emergency (PHE), it is via a new code that will lower the payments for these services.
  • While the new complexity code is a major step toward better valuing patient services, ACP is concerned that the code may be used less than is expected, given the need for education and awareness among physician practices. Reducing the estimated utilization would have helped to lessen the impact of the impending budget neutrality adjustment.
  • CMS also decided not to move forward with an evaluation of the codes used for payment for vaccines, leaving those reimbursements stagnant at 2019 levels. ACP has warned that the lower payment will not cover expected increase in costs associated with vaccine purchase, storage, administration, and record-keeping during a time when we will need to facilitate unprecedented vaccine administration coordination for the COVID-19 vaccine.

The rule does make several accommodations for COVID-19 that ACP believes are important. CMS will extend the use of virtual presence for physicians in training through at least the end of the year, or the end of the PHE. It also finalizes the primary care exception during the PHE and allows all levels of E/M services provided by resident physicians to be billed without the presence of a physician. Related, ACP is pleased that CMS permanently expanded the list of telehealth services as well as commissioned a study to research the effects of the COVID-19 telehealth flexibilities to better understand the experiences and learnings of both patients and physicians utilizing these revised policies.

Along with the MPFS, the Quality Payment Program (QPP) rule for 2021 was also finalized. In a positive move for physician practices under the Merit-based Incentive Payment System (MIPS), CMS will extend the extreme and uncontrollable circumstances hardship exception policy to 2021 as a response to the COVID-19 pandemic. This extension will allow physicians flexibility to prioritize patients amidst an international pandemic as COVID-19 cases increase around the country.

Despite the extension of the MIPS hardship exception, ACP has concerns with other aspects of the rule. The final rule rolls back important proposed flexibilities that would have make it easier for physicians to successfully participate in MIPS and will likely negatively impact participation in the program in 2021. Specifically, the final rule reverses a proposal to lower the MIPS performance threshold; reverses a proposal to use 2021 data to score quality measures and will instead rely on pre-pandemic benchmarks; and, increases the weight of the cost category without addressing longstanding concerns.

ACP also notes several areas of concern with the provisions related to the Advanced Alternative Payment Models (APM) pathway, as the rule fails to include any broad COVID-19 related protections for the thousands of physicians participating in APMs. CMS also finalized the new APM Performance Pathway for APM participants participating in MIPS, along with a number of quality reporting changes for Medicare Shared Savings Program participants that ACP worries could cause wide scale disruptions in reporting. Changes of this magnitude come at a particularly challenging time amidst the COVID-19 PHE, further complicated by the fact that physicians now only have 30 days to implement changes due to the delayed release of the final rule.

“Physician practices are under horrendous financial and emotional stress this year. Our health care system is ailing, and fault lines have formed.  I am deeply concerned about all of our patients and their access to care,” continued Dr. Fincher. “We need CMS to do as much as possible to support physicians in providing the best possible care to patients in this time of crisis.”


About the American College of Physicians
The American College of Physicians is the largest medical specialty organization in the United States with members in more than 145 countries worldwide. ACP membership includes 163,000 internal medicine physicians (internists), related subspecialists, and medical students. Internal medicine physicians are specialists who apply scientific knowledge and clinical expertise to the diagnosis, treatment, and compassionate care of adults across the spectrum from health to complex illness. Follow ACP on Twitter, Facebook, and Instagram.

Contact: Jacquelyn Blaser, (202) 261-4572,