Gastroenterology Coding Alert

Keep an eye on the upcoming changes, however.

GI practices have been keeping a close eye on CMS’ plans for 2019, particularly since the proposed Medicare Physician Fee Schedule suggested that some big changes could be on deck for the new year. Fortunately, nothing particularly dramatic will be coming your way in January, but some changes are lined up that could affect your coding in the future. Read on for the highlights of what CMS finalized in the 2019 Fee Schedule Final Rule.

Big E/M Changes Delayed

When CMS created its proposed rule for 2019, the agency had suggested making major changes to the outpatient E/M codes, which would have debuted a single payment rate for levels two through five office/outpatient services. However, that proposed change will not be finalized for 2019.

Here’s why: “Commenters largely objected to our proposal to eliminate payment differences for office/outpatient E/M visit levels 2 through 5 based on the level of visit complexity,” the MPFS noted.

Therefore, outpatient practices will continue coding and collecting using the current parameters and guidelines through 2020 -- but in 2021, revised options for the E/M requirements will be published.

You’ll also find the following changes that are scheduled to hit on Jan. 1:

• Update  home  visit  decision-making. Comments poured in from practitioners that they should be able to make the decision on whether to treat patients at home or in the office — without excessive documentation to prove the medical necessity for venue. CMS agreed and is nixing the requirement. These services fall under CPT^® codes 99341 to 99350, the MPFS noted.
• Accept staff notes. Instead of re-entering “chief complaint and history” data that “ancillary staff” already updated, physicians can plow ahead with E/M office/outpatient visits for both established and new patients, suggested the MPFS fact sheet.​
• Focus  on  patient  changes. Documenting new issues for established patients for office/outpatient visits is vital for quality care, and CMS will now allow providers to focus on that rather than information already in the medical record, especially if there’s evidence the physician reviewed the details, the agency said. “Practitioners should still review prior data, update as necessary, and indicate in the medical record that they have done so,” reminds the fact sheet. “It isn’t clear what sort of documentation will be needed for these purposes, but a statement (that could be part of a template, if selected service by service and not ‘cloned’ into every note) to the effect of ‘I personally reviewed and revised as medically necessary HPI, PMH, PFSH & ROS to be current’ is prudent,” said Glenn  D.  Littenberg,  MD,  MACP,  FASGE,  AGAF,   a gastroenterologist and former CPT^® Editorial Panel member in Pasadena, California.

• Cut  down  on  duplicates. The agency wants to simplify documentation for teaching physicians by removing “potentially duplicative requirements for notations,” particularly if residents or “other members of the medical team” have already uploaded their notes, the MPFS indicated. “This verbiage suggests that medical student evaluations will not have to be completely repeated by the attending physician,” Littenberg said. “Although no guidance was provided as to required level of documentation by the attending physician, there should be enough observations about key/clinically important aspects of history, exam, and decision-making to reflect substantive involvement by the attending staff during the encounter.”

Even the small rollbacks in 2019 will make a difference for providers struggling with too much administration. “There is little doubt that efforts to reduce regulatory burdens and simplify the documentation requirements for E/M visits will be welcomed by physicians and hospitals,” says attorney Benjamin Fee, Esq., of Dorsey and Whitney LLP in the Des Moines, Iowa office.

CMS Finalizes Virtual Care Options

CMS did boost its acceptance of tech-forward options with the decision to separately reimburse practitioners for two virtual care options.

Here is an overview of the two finalized HCPCS code choices:

• G2012 (Brief communication technology-based service, e.g. virtual check-in...)
• G2010 (Remote evaluation of recorded video and/or images submitted by an established patient...)

Important: The creation of these virtual service codes is to assist physicians in determining whether an in-person visit with the patient is warranted, indicates CMS in the final rule. Though they bolster more efficient care, these non-face-to-face codes come with a laundry list of documentation rules (i.e. patient must be established, service cannot lead to an E/M visit, and so on) that show medical necessity and are meant to curb “overutilization,” warns the agency. CMS notes in the MPFS guidance that it plans on “monitoring” providers’ usage closely.

Although a telephone or video visit could not be reported separately for an issue handled during a face-to-face visit within the prior seven days, the language suggests that if a different (not related) issue came up, it could warrant separate reporting of a service that typically would take five to 10 minutes of patient interaction, Littenberg said. “For both G codes, recording the time spent and the documen­tation required for medical necessity are important.”

Interprofessional Services Get Revisions, New Codes

You’ll have some changes to interprofessional telephone/internet services in the new year that were recently finalized in the CY 2019 MPFS as well.

Revisions: The revisions focus mainly on the inclusion of “electronic health record” into the descriptor. Moreover, according to the final rule, these previously bundled codes will now be paid separately, too. The CPT^® codes are as follows:

• 99446 — Interprofessional telephone/Internet/electronic health record assessment and management service provided by a consultative physician, including a verbal and written report to the patient’s treating/requesting physician or other qualified health care professional; 5-10 minutes of medical consultative discussion and review
• 99447 — … 11-20 minutes of medical consultative discussion and review
• 99448 — … 21-30 minutes of medical consultative discussion and review
• 99449 — … 31 minutes or more of medical consultative discussion and review.

New codes: Meanwhile, you can add the following two codes to your CPT^® checklist that primarily focus on a written report and referral service:

• 99451 — Interprofessional telephone/Internet/electronic health record assessment and management service provided by a consultative physician, including a written report to the patient’s treating/requesting physician or other qualified healthcare professional, 5 minutes or more of medical consultative time
• 99452 — Interprofessional telephone/Internet/electronic health record referral service(s) provided by a treating/requesting physician or other qualified healthcare professional, 30 minutes.

Resource: Read the 2,378-page MPFS CY 2019 final rule at https://s3.amazonaws.com/public-inspection.federal­register.gov/2018-24170.pdf.