EM Coding Alert

But documentation relief is on its way, says CMS.

On Nov. 1., the Centers for Medicare and Medicaid Services (CMS) published its 2019 Medicare Physician Fee Schedule (MPFS) Final Rule, and while the long-awaited revisions to the current office/outpatient E/M visit levels did not materialize, there was still a lot in the document to unpack, including a ruling to reduce E/M documentation requirements and an expansion to telehealth services.

Here are the three most significant takeaways from the 2,378-page document that you need to know.

No Change to E/M Levels Until 2021 (Maybe)

One area of the Final Rule that coders were anxiously awaiting involved changes to the current E/M system. Initially, CMS had proposed a two-tiered system for new and established patient E/M office/outpatient visits that would leave the current level one as it is and blend payments for current levels two through five into another, second level.

The proposal received a lot of pushback from many of the large medical associations, leading CMS to put a new proposal for a three-tiered system on the table that would keep current levels one and five intact while blending levels two through four. But this is still, effectively, only a proposal, and CMS has indicated in the Final Rule that it will continue its “discussions with the public… to potentially further refine … policies, through future notice and comment rulemaking.”

Most important for the time being, perhaps, is CMS’s promise that no changes to the current E/M system will take place until 2021. This has led many stakeholders to breathe a sigh of relief.

“This is probably good news for physicians, since it gives the physician community more time to work with CMS on this issue,” says Kent Moore, senior strategist for physician payment at the American Academy of Family Physicians.

“Not only would this have thrown a wrench into current payer schedules, it would also have had a big impact on physician offices and their staff,” adds Chelle Johnson, CPMA, CPC, CPCO, CPPM, CEMC, AAPC Fellow, billing/credentialing/auditing/coding coordinator at County of Stanislaus Health Services Agency in Modesto, California. “So, I am pleased to see the delay by CMS to move forward with these changes. Allowing the community a chance to catch up and prepare for the changes will be a benefit in the long run,” Johnson believes.

Taming the Beast of Administrative Burden

The 2019 Final Rule did demonstrate CMS’s growing commitment to reduce the burden of documenting E/M encounters. Beginning Jan. 1, you and your provider will no longer have to:

• Document medical necessity for a home visit instead of an office visit;
• Re-record a defined list of required elements in the medical record if there is evidence that the physician reviewed the previous information and updated it as needed; instead, the physician must just document what has changed since the last visit, or pertinent items that have not changed;
• Document the patient’s chief complaint and history if it has already been entered by ancillary staff or the beneficiary — again, the physician may simply indicate in the medical record that he or she reviewed and verified this information; or
• Duplicate notations that may have previously been included in medical records by residents or other members of the medical team for E/M visits furnished by teaching physicians.

This “documentation relief is more good news,” says Moore, reflecting the opinion of many in the coding world. And while the rules “may currently seem a little vague, and individual offices may interpret this information in a variety of ways, the rules will provide each of us with opportunities to question and fine tune them, eventually leading to more precise guidelines, which will ultimately help the industry,” says Johnson.

Telehealth Expansion Continues at Full Speed

The Final Rule also added two new HCPCS codes that you can add to your telehealth code list on Jan. 1. You’ll be able to use the first, G2012 (Brief communication technology-based service, e.g. virtual check-in, by a physician or other qualified health care professional who can report evaluation and management services, provided to an established patient, not originating from a related E/M service provided within the previous 7 days nor leading to an E/M service or procedure within the next 24 hours or soonest available appointment; 5-10 minutes of medical discussion), as a virtual patient check-in.

Importantly, in the past, CMS did not pay separately for such services and considered them bundled into other services, such as office visits, for which Medicare did pay. Now, CMS will pay separately for this service, which can be furnished using “real-time telephone interactions in addition to synchronous, two-way audio interactions that are enhanced with video or other kinds of data transmission.”

Similarly, you can use G2010 (Remote evaluation of recorded video and/or images submitted by an established patient (e.g., store and forward), including interpretation with follow-up with the patient within 24 business hours, not originating from a related E/M service provided within the previous 7 days nor leading to an E/M service or procedure within the next 24 hours or soonest available appointment) for services independent of an E/M visit. If the data originates from an E/M service within the previous seven days or initiates an E/M service, then the remote evaluation will be regarded as bundled into the E/M visit.

CMS also notes that G2010, like G2012, may only be used for an established patient and that the “scope of this service is limited to the evaluation of pre-recorded video and/or images.”

For the full text of the 2019 MPFS final rule, go to: s3.amazonaws.com/public-inspection.federalregister.gov/2018-24170.pdf.