Eyeworld

10 | EYEWORLD | APRIL 2020 ASCRS NEWS Association, the surgical community, and bipar- tisan members of Congress. In addition, CMS finalized an E/M add-on code for patients with complex or chronic disease that was a holdover meant to counteract expected payment reduc- tions for primary care from its now-abandoned proposal to collapse E/M levels 2–4. ASCRS and the surgical community main- tain that CMS' policy not to increase the global surgery postoperative E/M visits violates cur- rent law by creating an illegal specialty payment differential. The Medicare statute requires that physicians providing the same services be paid the same. Therefore, since 10- and 90-day glob- al codes include E/M—such as the three post- operative visits included in the recently revalued cataract code—they should be paid at the same rate. In addition, every time standalone E/M visits have been increased in the past, so have those in global codes. The impact on ophthalmology ASCRS partnered with the surgical commu- nity to study the potential impact of CMS' E/M policies for 2021. Because of the budget neutral nature of the physician fee schedule, the increase in value of the standalone codes and the add-on will have a significant redistributive impact: shifting value from surgical special- ties to primary care. Since the E/M codes and add-on will add so many relative value units (RVUs) to the fee schedule, CMS will have to decrease the conversion factor considerably to maintain budget neutrality. This will reduce the reimbursement of every single code in the fee schedule. While primary care will still see a sig- nificant payment increase over 2020, all surgical specialties and those that do not perform E/M will experience a payment decrease. Ophthal- mology is one of the hardest hit specialties. Despite concern about the impact of the E/M increase, it is important to remember that any ophthalmologist or optometrist who bills a standalone E/M beginning in 2021 will be reimbursed at the higher level. Eye codes are not currently impacted by this policy; however, we are advocating that they also be increased A ll surgical specialties, particularly ophthalmology, are facing steep across-the-board cuts to reimburse- ment—through a reduction in the conversion factor—if the Centers for Medicare and Medicaid Services (CMS) 2021 policies for evaluation and management (E/M) go into effect with- out modification. ASCRS has joined with the American College of Surgeons and the sur- gical coalition to advocate that the increased standalone values for E/M services should also be applied to postoperative E/M services included in 10- and 90-day global codes. Our original position also included the elimination of the E/M add-on code. However, due to the COVID-19 pandemic and potential to tap into the COVID-19 stimulus package, the surgical community advocated for the suspension of budget neutrality requirements for E/M policy changes for 2021 included in the 2020 Medicare Physician Fee Schedule final rule, which would increase the value of postoperative E/M ser- vices included in 10- and 90-day global codes, implement E/M add-on codes for patients with chronic disease, and prevent major reimburse- ment reductions to surgery to pay for primary care increases. Unfortunately, this was not included in the final stimulus package, the CARES Act, but ASCRS and the surgical community plan to continue to advocate to get this included in future COVID-19 packages. In addition, we are encouraging CMS to implement this change, without a congressional mandate, to alleviate the negative financial impact the pandemic is having on physicians and their practices. Below are complete details on the multipronged advo- cacy campaign. The issue Effective 2021, CMS finalized a policy to increase the value of standalone E/M codes. CMS did not, however, apply that same in- crease to the value of postoperative E/M visits included in 10- and 90-day global codes, despite advocacy from ASCRS, the American Medical Ophthalmology at risk for significant cuts from 2021 E/M changes continued on page 12

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