Practice Management Alert

Look beyond fees to code changes as well.

With payment and policy changes that could impact your practice this year, you can’t afford to miss relevant details from the 2019 Medicare Physician Fee Schedule (MPFS) final rule.

The rule should provide “dramatic improvements for clinicians and patients,” according to Sema Verma, CMS Administrator, and “move us closer to a healthcare system that delivers better care for Americans at lower cost,” according to Alex Azar, Health and Human Services (HHS) Secretary, in the CMS press release on the rule.

That’s the official view, but you should read on to get our expert perspective on some details of the rule.

Expect Minor Physician Pay Changes

The schedule-wide MPFS pay change comes in the form of the 2019 conversion factor (CF) increase to 36.0391, compared to the 2018 CF of 35.9996. The change is based on the budget-neutrality adjustment required by law, which accounts for changes in procedure codes’ relative value units (RVUs).

Coder tip: “The conversion factor, multiplied by a code’s RVUs and regional adjustment gives you the Medicare fee,” explains R.M. Stainton Jr., MD, president of Doctors’ Anatomic Pathology Services in Jonesboro, Ark. The code’s RVU is the total of physician work, practice overhead and malpractice expense.

Status quo: CMS estimates that overall, some practices will see pay increases, some will see decreases, and others will see no pay adjustment from the 2019 MPFS changes, despite the CF increase. Take a look at the following snippet of specialties to see where your practice falls.

If you don’t see your specialty in this table, you can review Table 94 in the Federal Register publication of the final rule here: https://www.govinfo.gov/content/pkg/FR-2018-11-23/pdf/2018-24170.pdf.

Caveat: The actual payment impact for your specific practice could vary up or down from that projection depending on the specific procedures and volumes you perform.

CMS Finalizes Virtual Care Options

CMS boosted 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, 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)
• 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)

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, says Glenn D. Littenberg, MD, MACP, FASGE, AGAF, a former CPT^® Editorial Panel member in Pasadena, California. “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 health care 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 health care professional, 30 minutes).