EM Coding Alert

Is the long-awaited shake-up finally on its way?

“This Administration has listened and is taking action,” was Centers for Medicare and Medicaid (CMS) Administrator Seema Verma’s bold proclamation in a press release that accompanied the July 12 release of the proposed Medicare Physician Fee Schedule (MPFS) for CY 2019.

“Physicians tell us they continue to struggle with excessive regulatory requirements and unnecessary paperwork that steal time from patient care. … The proposed changes to the Physician Fee Schedule and Quality Payment Program address those problems head-on, by streamlining documentation requirements to focus on patient care and by modernizing payment policies so seniors and others covered by Medicare can take advantage of the latest technologies to get the quality care they need,” Verma added.

Many of these changes involve changing the way you will document E/M services beginning Jan. 1, 2019. While the proposals are still being debated and won’t see their definitive form until the Final Rule is released later this year, here is a first look at all the changes that may well change your E/M reporting for the better in 2019.

Check Out These E/M Changes

CMS has been compiling stakeholder feedback on overhauling E/M services for a while now, but the suggested changes go way beyond dropping one of the three documentation requirements. In fact, the proposed MPFS pinpoints “a number of coding and payment changes to reduce administrative burden and improve payment accuracy” that CMS would like to implement in 2019, notes CMS’s MPFS fact sheet.

Those “historic” E/M documentation propositions that CMS presents include

• Using medical decision-making or time for outpatient E/M versus the current guidelines;
• Giving physicians the option of using time “as the single factor in all E/M visits, not just when counseling or care coordination dominate a visit”;
• Putting re-documenting aside and letting providers “focus their documentation on what has changed since the last visit or on pertinent items that have not changed”; and
• Giving practitioners the option of accepting data plugged in by staff instead of timely re-entering.

“CMS says this would simplify, streamline and offer flexibility in documentation requirements for these types of visits, which make up for 20 percent of allowed charges under the PFS,” indicates law firm Hall Render in analysis on its Health Law News blog. “The proposed rule changes the current system of four sets of documentation requirements and reduces it to a single set of documentation requirements.”

Important:  Over the years, CMS has received public commentary that suggests “E/M codes need substantial updating and revaluation to reflect changes in the practice of medicine,” states the MPFS proposal. After numerous listening sessions this past spring, CMS designed a plan to rework the E/M rules, keeping EHRs in mind for the documentation standards, but also to create “new, single blended payment rates for new and established patients for office/outpatient E/M level 2 through 5 visits and a series of add-on codes to reflect resources involved in furnishing primary care and non-procedural specialty generally recognized services,” informs the fact sheet.

What this means: Some specialties will likely suffer greatly with the relative value units (RVUs) of these much-used E/M codes set at a single payment rate, the MPFS says. So instead of varying rates for the codes as their complexity increases, CMS advises in the proposal that the payments would be the same.

For example, Medicare pay for E/M codes 99211 through 99215 would be straight across the board at $93 while 99202-99205 would all equal $135, the MPFS shows in Tables 19 and 20. A “multiple procedure payment adjustment” in addition to various “HCPCS G-code add-ons” and other factors would impact the eventual end payment, with some clinicians slated for financial gain or losses depending on the specialty, the MPFS suggests.

Stay tuned for more in-depth E/M analysis in future issues of E/M Coding Alert.

Resource: For a closer look at the MPFS proposed rule for CY 2019, visit s3.amazonaws.com/public-inspection.federalregister.gov/2018-14985.pdf.