The 2019 Medicare Physician Fee Schedule proposed rule would apply a single payment rate system for Level 2-5 office and outpatient evaluation and management (E/M) visits in exchange for reduced documentation requirements, according to an AOA public policy analysis of the recently released 1,400-page draft rule.
Specifically, CMS proposes to give physicians three options for documenting those visits.
Those who wish to take advantage of the streamlined paperwork can either (1) document medical decision making or (2) record the amount of time spent with the patients. They can also (3) stick with the current 1995 or 1997 CMS guidelines to determine the level of E/M visit, continuing with existing documentation requirements.
The proposed payment rates would apply regardless of the documentation style the physician selects. If adopted, the proposal would apply single payment rates to CPT codes 99202-99205 and 99212-99215, while accepting a documentation standard similar to that of a current Level 2 visit, unless time is used as the determining factor.
Current/proposed payment rates for new patient office/outpatient visits
|New patient CPT code||Current payment rate||Proposed payment rate|
|99201 (Level 1)||$45||$44|
|99202 (Level 2)||$76||$135|
|99203 (Level 3)||$110||$135|
|99204 (Level 4)||$167||$135|
|99205 (Level 5)||$211||$135|
Current/proposed payment rates for established patient office/outpatient visits
|Established patient CPT code||Current payment rate||Proposed payment rate|
|99211 (Level 1)||$22||$24|
|99212 (Level 2)||$45||$93|
|99213 (Level 3)||$74||$93|
|99214 (Level 4)||$109||$93|
|99215 (Level 5)||$148||$93|
Streamlined paperwork explained
Under the proposed rule, documentation for established patient visits would focus on what has changed since the last visit or on pertinent items that have not changed. Physicians would not have to re-document a defined list of required elements, such as review of a specified number of systems and family/social history.
For both new and established patients, physicians would be able to review and verify the chief complaint and history information recorded by ancillary staff or the beneficiary, instead of having to re-enter the information.
The rule would also amend documentation requirements for teaching physicians, allowing the physician, resident or nurse to input the extent of the physician’s participation into the medical record. Current regulations require the teaching physician to personally document their participation.
CMS also proposes a new add-on HCPCS G-code to reflect the complexity and additional resources associated with certain types of primary care services. The code, known as GPC1X, would cover primary care focused on complex medical issues that affect all of the patient’s health care services, such as treatment of diabetes.
An additional new add-on HCPCS G-code is proposed for specialties including endocrinology, rheumatology, hematology/oncology, urology, neurology, obstetrics/gynecology, allergy/immunology, otolaryngology, cardiology, or interventional pain management care.
CMS would also develop new HCPCS G-codes for prolonged E/M or psychotherapy services.
Members of the AOA Bureau of Socioeconomic Affairs will review the proposed rule later this week.