CMS may be changing the E & M code family in 2019. At this time, the changes are open for debate and feedback.
The link to the CMS announcement is here: CMS Announcement
You may review the changes yourself by clicking here DEPARTMENT OF HEALTH AND HUMAN SERVICES and starting at page 374.
Some of the key changes that are proposed could have dramatic affects to providers in a variety of different ways. Ultimately, the proposed E/M changes impact physicians differently. Physicians that see more complex patients—level 4 and 5 E/M visits—are impacted more than those who typically see levels 1, 2, and 3. CMS argues the negative financial impacts will be offset by the reduction in administrative burdens as outlined in the proposed rule. This may ultimately be true for some specialties, but for others it comes at a price.
Specifically, CMS has said “most specialties would see changes in their overall Medicare payments in the range of 1-2 percent up or down from this policy, but we believe that any small negative payment adjustments would be outweighed by the significant reduction in documentation burden. If you add up the amount of time saved for clinicians across America in one year from our proposal, it would come to more than 500 years of additional time available for patient care, ” as Administrator Verma wrote in her letter to physicians.
Some of the proposed changes:
1. Lifting Restrictions Related to E/M Documentation
a. Eliminating Extra Documentation Requirements for Home Visits: Required documentation showing medical necessity for home visits rather than an office visit will be eliminated.
b. Eliminate Restriction of only one E/M visit per day: As integration of care from multiple specialties into one organization has expanded, this has created problems.
2. Changing Documentation Requirements for Office or Other Outpatient E/M Visits and Home Visits
a. Flexibility in Documentation Options: Providers may choose either Medical Decision Making (MDM), time, or current guidelines (1995 or 1997) as the basis to determine the appropriate level of an E/M visit. Regardless of the method chosen, the payment rate is the same.
b. New Specialty-Specific E/M Codes: Some specialties will have their own E/M codes assigned (new G codes) to describe their services. For example, the proposed rule has two new codes for podiatry E/M services for the initiation of treatment which will be priced similar to ophthalmological service codes 92004 and 92012.
c. Value of Time: Providers may use time as the determining factor regardless of whether or not counseling or care coordination was more than 50 percent of the face-to-face encounter. They are still determining how to best report situations where the time is significantly higher than the two tier payment rate being proposed. It might require the use of the Prolonged Services or other new codes.
d. Less Documentation Required: Providers only need to meet the documentation requirements of a level 2 visit for history, exam, and/or MDM (unless using time) to meet audit requirements. However, for clinical, legal, and operational purposes, it is wise to continue to meet current requirements.
Note: Even though there are reduced requirements, there are still basic standards that are expected for quality of care. Take social history for example. Even though it will no longer be required, it remains an important component to understand the patient's needs and situation to ensure that proper care is provided.
3. Removing Redundancy in E/M Visit Documentation: Remove the requirement to re-document information that is already in the patient's medical record. These aren't required changes. Providers may choose to continue to do things as they are currently doing them.
For established patients, the provider needs to only review and verify information and only document any new or changed elements of the review of systems (ROS) and/or past, family, and/or social history (PFSH) that are already in the record.
For both new and established patients, practitioners would no longer be required to re-enter information in the medical record regarding the chief complaint and history that are already entered by ancillary staff or the beneficiary. Instead, the provider will indicate that they reviewed and verified this information.
4. Minimizing Documentation Requirements by Simplifying Payment Amounts: There will only be two payment rates for E/M visits - Level 1 and Levels 2-5. There will be "new add-on codes to better capture the differential resources involved in furnishing certain types of E/M visits".
You will still bill the applicable level with the same CPT codes (99202-99205, 99212-99215), they will just be paid at the same rate. They basically averaged the rates currently being paid to come up with a single rate. While this may decrease revenues, the benefit is that it reduces the problem of audits and payback requests on these codes.
According to the proposed rule, there are three unique E/M visits (listed below) which do not fall under the basic E/M guidelines. There will be new HCPCS G codes assigned to report these services:
separately identifiable E/M visits furnished in conjunction with a 0-day global procedure
primary care E/M visits for continuous patient care
certain types of specialist E/M visits, including those with inherent visit complexity
If you would like to participate and provide feedback, you may do so in the following ways:
1. Submit electronic comments on this regulation to www.regulations.gov. Follow the instructions for “submitting a comment.”
2. Mail written comments to:
CMS-1676-P 2
Centers for Medicare & Medicaid Services, Department of Health and Human Services, Attention: CMS-1676-P
P.O. Box 8016
Baltimore, MD 21244-8013.
Allow sufficient time for mailed comments to be received before the close of the comment period.
3. By express or overnight mail. You may send written comments to:
Centers for Medicare & Medicaid Services, Department of Health and Human Services, Attention: CMS-1676-P
Mail Stop C4-26-05
7500 Security Boulevard
Baltimore, MD 21244-1850.
4. Deliver (by hand or courier) written comments before the close of the comment period to:
Centers for Medicare & Medicaid Services, Department of Health and Human Services,
Room 445-G, Hubert H. Humphrey Building,
200 Independence Avenue, SW., Washington, DC 20201
cited links:
https://www.chirocode.com/blog/274
https://www.cms.gov/Newsroom/MediaReleaseDatabase/Press-releases/2018-Press-releases-items/2018-07-12.html
https://www.policymed.com/2018/07/cms-proposed-evaluation-and-management-e-m-documentation-and-payment-changes-are-sparking-backlash-and-may-hurt-patients.html
https://www.aapc.com/blog/39245-cms-considers-revising-em-documentation-guidelines/