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Public Policy Newsletter Article

Biocom Comments on CMS’ Proposed 2021 Physician Fee Schedule

  • 2020-10-22T15:00:00.000+0000
  • Author: Laure Fabrega

On October 5, Biocom submitted comments in response to the Centers for Medicare and Medicaid’s (CMS) proposed Medicare Physician Fee Schedule and Quality Payment Program for 2021, which updates the payment rates for physician services and expands the list of telehealth services that Medicare covers.

Biocom’s letter addressed the following:

• Biocom supports CMS’s proposal to continue audio/video telehealth services for the duration of the PHE, and encourage the Agency to expand the list of Medicare telehealth services permanently.


• Biocom opposes CMS’ proposed clarification of “interactive communication” and calls on the Agency to align its interpretation of an “interactive communication” for purposes of CPT codes 99457 and 99458 to support a healthcare professional’s time in a calendar month providing RPM.


• Biocom strongly supports CMS’ proposal to adopt the E/M coding structure as revised by the AMA CPT Editorial Panel and accept the RUC-recommended values, including retaining the 5 separate levels of coding for established patients and 4 levels for new patients.


• Biocom urges CMS to add CPT code 96040 to the list of telehealth services and recognize genetic counselors as providers.

• Biocom applauds CMS for encouraging nonphysician practitioners, such as nurse practitioners, physician assistants, and clinical nurse specialists, and midwives, to order diagnostic tests. We are pleased that CMS has enabled pharmacists to order testing for COVID-19 during the current public health emergency and recommend extending this scope of practice further to other diagnostic tests, including pharmacogenomics tests so that they may further assist with medication management consultations.

If you have any questions, please contact Laure Fabrega, Director of Federal Policy and Government Affairs at [email protected].