Ophthalmology and Optometry Coding Alert

The agency seeks feedback on how these changes would impact your practice.

With summer about to end, it's time for CMS to begin preparing for the New Year - and that means releasing the 2018 proposed Medicare Physician Fee Schedule, which recommends updates to the Part B payment policy. The proposals could be significant for eye care practices, since some of the biggest revisions involve completely overhauling how E/M codes are selected, which could affect whether you turn to these codes at all or stick with the ophthalmic examination codes instead.

Check out These E/M Proposals

The proposed rule indicates that CMS is looking at updating the E/M code requirements for the first time in decades. "We are specifically seeking comments on how we might focus on initial changes to the guidelines for the history and physical exam because we believe documentation for these elements may be more significantly outdated, and that differences in medical decision-making (MDM) are likely the most important factors in distinctions between visits of different levels," CMS says on page 377 of the proposal.

CMS is not only suggesting that it might lean more heavily on MDM when selecting an E/M level, but even appears to be considering eliminating history and physical exam documentation requirements entirely. "We are also specifically seeking comment on whether it would be appropriate to remove our documentation requirements for the history and physical exam for all E/M visits at all levels," the proposal says. "We believe medical decision-making and time are the more significant factors in distinguishing visit levels, and that the need for extended histories and exams is being replaced by population based screening and intervention, at least for some specialties."

Strong MDM, Time Components Could Be the New Normal

CMS' proposal may be shocking to many in the coding industry, but could have many positive impacts if finalized. The proposal that time would be more important in selecting an E/M code could be helpful in some cases, said Catherine du Toit, CPC, CPMA, CGIC of Clean Claims Coding Consultants.

This change could be especially helpful to those practices that see patients with extremely complex diagnoses, since this requires the doctors to spend a significant amount of time speaking with patients and their families about treatment options and prognosis issues for conditions like glaucoma and blindness. In these situations, E/M code levels are often selected based on time as the controlling factor. If CMS makes it easier to code based on time, these eye care practices could find code selection faster and easier.

Submit Comments to Have Your Say

Although some practices are cheering the lower documentation burden that this could create, others are questioning why CMS would loosen the requirements for an area of coding that already has challenges. "Removing the history and physical (H&P) component from coding guidelines is like having a tree with no 'roots,'" suggests Vinod Gidwani, president of full-service revenue cycle firm Currence, based in Skokie, Illinois. "The H&P determines the level of medical decision-making as well as the time component. Removing the H&P is like determining the MDM and time components in a vacuum," Gidwani says.

No matter where you stand on this issue, CMS wants to hear from you. "We are seeking comment on whether clinicians and other stakeholders believe removing the documentation requirements for the history and physical exam would be a good approach," the agency says in the proposal.

If your practice has an opinion on this matter, now is a good time to submit your comments, which are due by Sept. 11, 2017. You can either submit online at www.regulations.gov (referencing CMS-1676-P), or by mail or in person.

Resource: To read the proposed fee schedule, visit https://s3.amazonaws.com/public-inspection.federalregister.gov/2017-14639.pdf.