ED Coding and Reimbursement Alert

If the proposal is finalized, you could collect more for E/M services in the ED.

Some years, the Medicare Physician Fee Schedule (MPFS) proposal can strike fear and trepidation, while other years, the document provides much-needed relief for EDs.Fortunately, this year could lean more toward the latter scenario, with proposed pay for emergency department E/M services potentially on the rise effective Jan. 1.

Background: CMS released its proposed MPFS for 2020 on July 29, and it includes scores of changes that the agency is considering putting into effect on Jan. 1, 2020. Keep in mind that these are suggestions — nothing has been finalized yet —but if you feel strongly about any of the topics in the proposal, you should submit comments to CMS by Sept. 27.

CMS Could Revalue E/M Codes

Among the most promising proposals in the document is the revaluing of ED E/M codes 99281-99285 (Emergency department visit for the evaluation and management of a patient …). This stems from a notation in the 2018 MPFS Final Rule, which nominated the codes in this series as potentially mis-valued codes. The AMA Relative Value Scale Update Committee (RUC) subsequently reviewed the work that goes into furnishing these services, and the 2020 proposal suggests that CMS will accept the following RUC-recommended work RVUs (also known as RVWs) for the ED E/M codes:

Work RVU Proposed Changes

You’ll note that the work RVUs increased for every code except 99285 —for that code, the number stayed the same. This is because the time associated with 99285 was reduced based on the 2018 survey responses, but the RUC and CMS acknowledged that the intensity for that service had increased. Therefore, the proposed value for 99285 remained the same, since the RUC values are based on intensity over time to justify the assigned RVUs. Even so, increases in the professional liability insurance RVUs for 99285 along with a proposed increase in the conversion factor for 2020 should still result in modest increases in payments for that service, says David A. McKenzie, CAE, reimbursement director at the American College of Emergency Physicians.

Proposed Payment Changes

If this proposal is finalized, the higher RVUs could end up allowing EDs to collect significantly more for these commonly performed services.

Caution: However, the ED E/M increase could well be impacted by statutory budget neutrality adjustments due to increased RVU assignments to other codes. Tables in the proposed rule outlining different scenarios show emergency medicine having an overall Medicare allowed payment impact of between plus one percent and minus seven percent. Stay tuned to see what the final rule reveals for what we can expect in 2020.

Reducing Documentation Burden

Another proposal that has caught the eye of many EDs is a notation in the proposed fee schedule to decrease the documentation burden on practitioners. “The physician may review and verify (sign/date), rather than re-document, notes in a patient’s medical record made by physicians, residents, nurses, students, or other members of the medical team including, as applicable, notes documenting the physician’s presence and participation in the services,” the proposal states.

This would free up time and ensure that practitioners would no longer have to restate what’s already been noted in the record.

Resource: To read the complete proposed rule, visit  https://s3.amazonaws.com/public-inspection.federalregister.gov/2019-16041.pdf.