Published December 23, 2020

Top Five Medicare Reimbursement Takeaways from the Coronavirus Response and Relief Supplemental Appropriations Act, 2021

Updated 12/28/20.


On Sunday, December 27th, the Coronavirus Response and Relief Supplemental Appropriations Act, 2021 was signed into law. Included in the Act are material changes to several programs and activities affecting those in healthcare including changes to aspects of the CARES Act Provider Relief Fund (PRF), the Payroll Protection Program (PPP), the 2021 Medicare Physician Fee Schedule, and out-of-network billing. This is the third in a series of articles that PYA will release breaking down the impact of the legislation on these key areas impacting our clients.

Somewhat unexpectedly, Congress included several provisions that impact Medicare reimbursement for 2021. Key provisions include the following:

  • 3.75% increase in reimbursement for physician services. In response to the anticipated financial impact of payment decreases included in the 2021 Medicare Physician Fee Schedule (MPFS), the legislation includes a one-time 3.75% increase in the 2021 fee schedule. Congress notes that this is “in order to support physicians and other professionals in adjusting to changes in payment for physicians’ services during 2021”.
  • Moratorium on payment of CPT G2211. The 2021 MPFS included payment for G2211, an add-on code that acknowledges “visit complexity inherent to E/M associated with medical care services that serve as the continuing focal point for all needed health care services and/or with medical care services that are part of ongoing care related to a patient’s single, serious, or complex chronic condition.” Use of this code was expected to be high, bringing with it significant financial implications. The legislation institutes a moratorium on the payment of this code until January 1, 2024.
  • Extension of suspension of temporary sequestration. Medicare sequestration was originally suspended through December 31, 2020 in response to the public health emergency (PHE). With this legislation, the suspension is extended through March 31, 2021.
  • Frozen thresholds related to Advanced Alternative Payment Models (APMs). The legislation temporarily freezes the APM payment incentive thresholds through 2024.
  • Delay of Radiology Oncology Mandatory Bundled Payment Program (RO Model). This new payment model was originally slated to begin on January 1, 2021. In October, the effective date was delayed to July 1, 2021. This legislation indicates that this model, or any substantially similar model, may not be implemented before January 1, 2022.

The legislation further includes substantive changes impacting critical access hospitals, Rural Health Centers and Federally Qualified Health Centers, and graduate medical education residency positions. These items will be addressed in future articles.

If you have questions about PRF payments and reporting or would like guidance for other COVID-19 matters, visit PYA’s COVID-19 hub, or contact a PYA executive below at (800) 270-9629.

Executive Contacts

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