Pediatric Coding Alert

CMS reduces administrative burden, keeps current E/M guidelines — for now.

There’s a lot of good news for coders in the 2019 Medicare Physician Fee Schedule (MPFS) Final Rule. For one thing, the Centers for Medicare and Medicaid Services’ (CMS) decision to delay changes to the current evaluation and management (E/M) system means business as usual for determining E/M visit levels in the new year — you won’t need to change templates or update protocols just yet.

More on that later.

But the E/M guidelines delay isn’t the only reason for you to cheer. Beginning Jan. 1, you and your provider will be able to take advantage of CMS’ decision to reduce your E/M paperwork. Read on and see if your workload is going to be lighter in 2019.

“Patients Over Paperwork”

On Oct. 26, 2017, CMS launched an initiative called “Patients over Paperwork,” “in accord with President Trump’s Executive Order that directs federal agencies to ‘cut the red tape’ to reduce burdensome regulations” (Source: www.cms.gov/Outreach-and-Education/Outreach/Partnerships/Downloads/PoPDecember2017Newsletter.pdf). One year in, and CMS has begun to follow through on the promise.

Its first efforts, published in the 2019 Final Rule, focus on removing “potentially duplicative requirements for certain notations in medical records that may have previously been documented by residents or other members of the medical team” (Source: www.cms.gov/About-CMS/Story-Page/Clinician-Letter-Reducing-Burden-Documentation-and-Coding-Reform-.pdf).

Significantly, the Final Rule tries to help you do this in four specific ways:

1. If a medical student working in your practice writes notes in a patient’s medical record, your provider will no longer have to rewrite the note. Instead, your provider can simply sign off on the note, and you can then use it for billing purposes.

2. Your provider will now no longer have to re-enter a chief complaint or historical information into the medical record if it has already been entered by a new or established patient or a member of your practice staff. Instead, your provider will simply have to review the information and verify that it is correct.

3. Similarly, your provider will not have to redocument an established patient’s history and exam if it is already in the medical record. Instead, your provider will simply have to document anything that has changed since the patient’s previous visit.

Finally, your provider will no longer have to document medical necessity when visiting a patient at the patient’s home if the patient is unable to visit your office.

Experts Weigh In

The coding community have received these new documentation guidelines with almost unanimous approval. This “documentation relief is good news,” says Kent Moore, senior strategist for physician payment at the American Academy of Family Physicians.

Some experts, however, have voiced a note of caution. The new rules “currently seem a little vague, and individual offices may interpret this information in a variety of ways,” notes Chelle Johnson, CPMA, CPC, CPCO, CPPM, CEMC, AAPC Fellow, billing/credentialing/auditing/coding coordinator at County of Stanislaus Health Services Agency in Modesto, California. However, Johnson takes a long-term view of the changes. In the end, “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,” Johnson believes.

So, What Happened to the Proposed E/M Level Changes?

Well, if you were expecting CMS to finalize its revisions to the E/M office/outpatient guidelines, the 2019 Final Rule will leave you disappointed. For the time being, CMS has backed down over its original proposal of blending payments for current E/M levels two through five and has delayed any change until 2021 at the earliest.

Despite their frustration that the E/M situation has yet to be resolved, the news came as a welcome relief to members of the coding community. “I am pleased to see the delay by CMS to move forward with these changes,” says Johnson, echoing the thoughts of many. “They would have thrown a wrench into current payer schedules, as well as having a big impact on physician offices and their staff. The delay will allow the community a chance to catch up and prepare for the changes, which will be a benefit in the long run,” Johnson believes.

“This is probably good news for primary care physicians, since it gives the physician community more time to work with CMS on this issue,” agrees Moore.

But the 2019 MPFS Final Rule isn’t the final word on the matter. CMS has put on the table a new proposal for a three-tiered system, which would keep current E/M levels one and five intact, while blending levels two through four.

Whether that will happen remains to be seen. In the meantime, CMS has asked for more “discussions with the public … to potentially further refine … policies, through future notice and comment rulemaking.”

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

To sign up for Patients Over Paperwork newsletter alerts and view previous newsletters, go to www.cms.gov/About-CMS/story-page/patients-over-paperwork.html.