Yesterday, the Centers for Medicare & Medicaid Services (CMS) released for public inspection the Medicare Physician Fee Schedule Final Rule for calendar year 2019, announcing modifications to its proposals for office and outpatient Evaluation and Management (E/M) visits for new and established patients.
CMS adopts AOA recommendations
The AOA applauds CMS for adopting several recommendations made by the AOA and other stakeholder groups that will provide immediate relief of burdensome and duplicative documentation requirements, and for delaying implementation of final payment policy changes.
“The two-year delay will allow the AOA time to continue working with CMS to refine E/M policy changes in the best interests of patient care prior to implementation,” says AOA President William S. Mayo, DO.
CMS did not finalize proposals to allow same-day billing by the same practitioners of the same group or specialty, create new codes for podiatry visits, or create a single PE/HR value for E/M visits.
50 percent pay cut averted
CMS also did not finalize its proposal to adopt a multiple procedure payment adjustment. This means that osteopathic manipulative treatment codes will not be subjected to a 50 percent cut when with billed with an E/M visit appended with Modifier 25.
In addition to direct engagement with CMS and collaboration with other stakeholder groups, the AOA facilitated the submission of comments by more than 1,000 practicing DOs.
“The AOA is grateful that CMS heeded the concerns expressed by practicing physicians about the proposed rule and looks forward to advancing the dialogue on how physician payment policy can be modified for the betterment of both physician practice and the patients we care for,” Dr. Mayo says.
Effective Jan. 1, 2021, the following changes will apply:
- CMS will pay a single rate for Levels 2-4 office/outpatient E/M visits ($130 for new patients and $90 for established patients).
- Level 5 E/M visits will not be included in the collapsed payment rates as proposed.
- CMS will allow clinicians the option to use 1995 or 1997 guidelines, medical decision making (MDM) or time for Levels 2-5 office/outpatient E/M visits.
- Clinicians can document Level 5 visits based on time as an alternative.
- Clinicians billing Levels 2-4 office/outpatient E/M visits will only have to meet documentation requirements consistent with a Level 2 visit if using 1995 or 1997 guidelines or MDM.
- CMS will establish new add-on codes for additional resources inherent to primary care (GPC1X) and non-procedural specialty care (GCG0X) visits for new and established patients. Physician time and work RVUs for both codes will be equal.
- CMS will create a new a code for extended visits (GPRO1).
Effective Jan. 1, 2019, the following changes will apply:
- CMS will continue the current coding and payment structure for E/M visits, allowing clinicians the option to use the 1995 or 1997 guidelines.
- Clinicians will no longer have to document medical necessity for home visits.
- Clinicians will not have to re-document history and physical for established patients, allowing documentation to focus only on what has changed since the last visit or on pertinent items that have not changed.
- Clinicians will no longer have to re-enter information in the medical record regarding chief complaint and history for new and established patients if the information has already been entered by ancillary staff or the patient.
- CMS will amend documentation requirements for teaching physician E/M visits to allow for the physician, resident or nurse to document the presence and extent of the physician’s participation in the medical record.
The final rule will be published in the Federal Register on Nov. 23, 2018. CMS will accept comments on the final rule until Dec. 31, 2018.
The AOA will continue to review the final rule and provide additional information regarding E/M and other policy changes to the Physician Fee Schedule and the Quality Payment Program.
Further details on the final rule are available in the CMS Fact Sheet published with the final rule.