The Centers for Medicare & Medicaid Services (CMS) recently released the CY 2019 Physician Fee Schedule Proposed Rule. While the rule has yet to be finalized, the proposal indicates the overall changes CMS plans to implement in the coming year and in subsequent years. Proposed changes include relaxed documentation requirements for physicians’ Evaluation and Management (E/M) services. However, there may also be changed reimbursement levels that could impact your bottom line.
Highlights of proposed changes include:
E/M Payment: A single payment rate for new and established patients for office/outpatient E/M level 2 through 5 visits (99202-99205 and 99212-99215) along with a series of add-on codes to reflect the necessary resources to provide primary care and nonprocedural specialty generally recognized services
E/M Guidelines (last updated in 1997) would:
- Allow practitioners the choice of documenting office/outpatient E/M visits using medical decision-making or time instead of applying the current 1995 or 1997 E/M documentation guidelines. Alternatively, practitioners could continue using the current framework.
- Expand current options by allowing practitioners to use time as the governing factor in selecting visit level and documenting the E/M visit, regardless of whether counseling or care coordination dominate the visit.
- Expand current options regarding the documentation of history and exam, to allow practitioners to focus their documentation on what has changed since the last visit or on pertinent items that have not changed, rather than re-documenting information, provided they review and update the previous information.
- Allow practitioners to simply review and verify certain information in the medical record that is entered by ancillary staff or the beneficiary, rather than re-entering it.
To meet consumer demand and advance the concept of virtual care, it is proposed that CMS:
- Pays clinicians for virtual check-ins (non-face-to-face)
- Pays clinicians for the evaluation of patient-submitted photos
- Expand Medicare-covered telehealth services to include prolonged preventive services
Electronic Health Records (EHRs):
The proposed changes are intended to reduce clinician burden, focus on outcomes and promote interoperability of EHRs by:
- Removing MIPS process-based quality measures that clinicians have said are low value or low priority to focus on meaningful measures that have a greater impact on health outcomes; and
- Overhauling the MIPS “Promoting Interoperability” performance category to support greater EHR interoperability and patient access to their health information, as well as to align this performance category for clinicians with the proposed new Promoting Interoperability Program for hospitals.
CMS is currently seeking comments on the implementation timeline of these proposals and on how E/M visit coding and documentation could be updated in other care settings in future years. The deadline for comments is Sept. 10, 2018. Goldin Peiser and Peiser will continue to keep you updated as the CY2019 Physician Fee Schedule is finalized.
Note: This content is accurate as of the date published above and is subject to change. Please seek professional advice before acting on any matter contained in this article.