As ACEP’s RUC advisors in 2018 when the 2020 codes values were considered, Ethan Booker, MD, FACEP, and Jordan Celeste, MD, FACEP, presented our data to the RUC for consideration and voting.
ACEP’s RUC advisor team also includes staff members David McKenzie, CAE, ACEP’s reimbursement director, and Adam Krushinskie, MHA, ACEP’s reimbursement manager, who conduct the detailed membership surveys as part of the RUC process. This team provides information and evidence for our RUC advisors to use during their presentations to the committee.
What Did ACEP Do for You?
In 2017, CMS identified the emergency department evaluation and management (E/M) codes as potentially mis-valued. These codes, which include five levels of complexity (Levels 1–5), are billed by the majority of our members and represent roughly 85 percent of emergency medicine services.
ACEP’s RUC team managed the RUC’s review of these codes, first surveying a random sample of ACEP members using a standardized RUC survey instrument and then using the survey results to develop recommendations for the RUC. The survey results are validated using comparisons of trusted existing codes with similar times and intensity to the codes under review. Supporting data from published research is also used to supplement the survey results and recommendations. As noted above, an increase in one specialty’s code results in decreasing another specialty’s code to ensure zero-sum-game budget neutrality. During the last RUC cycle, only approximately 9 percent of codes identified as potentially mis-valued received value increases.
Our advisors knew we had to provide a compelling argument to convince at least two thirds of the other RUC voting specialties to support our recommended values. Using the data collected through our member surveys, Dr. Booker and Dr. Celeste convinced the RUC the ED E/M codes were undervalued. The RUC approved increases of 1.5 percent to 6.5 percent for Levels 1 through 4. For now, Level 5 values will remain stable.
In the calendar year 2020 PFS proposed rule, CMS accepted the RUC’s recommendation. If this proposal is finalized in November, in 2020 we could see an increase in ED E/M Medicare payments of approximately $137 million annually, before any additional budget neutrality adjustments.
CMS has proposed to accept RUC’s recommendations, but CMS must finalize its proposal in the PFS final rule in November for these increases to become effective in 2020. ACEP annually submits extensive comments on the PFS proposed rule, and our comments this year will strongly urge CMS to finalize its proposal.