Re: Policies for Office/Outpatient E/M Visits in the CY 2021 Medicare
Physician Fee Schedule Proposed Rule
Dear Administrator Verma:
On behalf of the undersigned 26 organizations, we write to voice our strong opposition to certain
policies related to evaluation and management (E/M) codes in the calendar year (CY) 2021
Medicare physician fee schedule (PFS) proposed rule. The Centers for Medicare & Medicaid
Services (CMS) is proposing to reduce the Medicare conversion factor from $36.0896 to
$32.2605, or by 10.6 percent. This decrease lowers the 2021 conversion factor below the 1994
conversion factor of $32.9050, which would be approximately $58.02 today in current dollars.
This extraordinary cut to the conversion factor is triggered by a number of proposed increases to
the values of many bundled services that are comparable to or include office/outpatient E/M
visits. The additional spending to support these increases along with the increases to stand-alone
office/outpatient E/M visits totals $10.2 billion.
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