In response to Evaluation and Management (E/M) coding and payment changes proposed by the Centers for Medicare & Medicaid Services (CMS), the chairs of the American Medical Association CPT Editorial Panel and the AMA/Specialty Society RVS Update Committee (RUC) have formed an E/M Workgroup, which is made up of current and former CPT Panel and RUC members from different specialties.
The E/M Workgroup intends to develop a new E/M coding structure, while considering relativity issues for these office visit services. The goal of this group is to have a coding proposal submitted for consideration at the Feb. 7-8, 2019 CPT Editorial Panel meeting.
In August the E/M Workgroup held its first two meetings, and it continues to meet on a regular basis, allowing stakeholders to listen to workgroup discussions and offer questions and comments, at various times throughout the agenda. AASM members and staff have been joining in on the E/M Workgroup conference calls and will continue to monitor the workgroup activities to represent the interests of sleep specialists.
In the Proposed Rule for the 2019 Medicare Physician Fee Schedule, CMS is proposing several documentation, coding and payment changes, intended to reduce administrative burden and improve payment accuracy for E/M visits, in accordance with the Patients over Paperwork initiative. Some proposed changes include:
- Allowing practitioners to choose to document office/outpatient E/M visits using medical decision-making or time instead of applying the current 1995 or 1997 E/M documentation guidelines or, alternatively, practitioners could continue using the current framework;
- Expanding 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;
- Expanding current options for 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;
- Allowing 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;
- Establishing single blended payment rates for new and established patients for office/outpatient E/M level 2 through 5 visits and a series of add-on codes to reflect resources involved in furnishing primary care and non-procedural specialty generally recognized services;
- Establishing a multiple procedure payment adjustment to recognize efficiencies that are realized when E/M visits are furnished in conjunction with other procedures;
- Adding a new prolonged face-to-face E/M code, as well as a technical modification to the practice expense methodology;
- Eliminating the requirement to justify the medical necessity of a home visit in lieu of an office visit; and
- Eliminating potentially duplicative requirements for notations in medical records that may have previously been included in the medical records by residents or other members of the medical team, for E/M visits furnished by teaching physicians.
A CMS presentation is available to provide more information about the proposed E/M changes and the Patients over Paperwork initiative. Get more information from the AASM about coding and reimbursement.