CMS delays controversial E/M changes in final rule

 

After a torrent of criticism from the physician community, the Centers for Medicare & Medicaid Services has delayed its proposed collapsing of evaluation and management (E/M) codes into single payments.

The agency’s final 2019 Physician Fee Schedule, announced Nov. 1, rescinds a proposal that would have blended payments for new and established patients for office/outpatient E/M levels 2 through 5 into single payments. Instead, the agency will continue to hear perspective on the proposal with plans to collapse E/M code levels 2 through 4 into single payments beginning in 2021, while maintaining level 5.

CMS also pulled back its proposal to apply a multiple procedure payment reduction to E/M visits furnished on the same day as a procedure. Payment rates for the less expensive of the two will be maintained, rather than cut in half as initially proposed.

The American Academy of Dermatology Association (AADA) expressed appreciation that CMS took feedback from the physician community seriously and that the agency took steps to eliminate some of its proposals.

“The AADA appreciates the effort and willingness of key decision makers at CMS, at HHS, and on Capitol Hill to hear the concerns of dermatologists and other physicians, and to take them into consideration in developing this final rule,” George J. Hruza, MD, president-elect of the AADA said in an interview. “We appreciate that CMS decided against moving forward with the proposal to make aggressive changes to payment associated with modifier 25 – when an office visit and one or more procedures are provided to a patient on the same day. We are also pleased that CMS made the decision to delay its larger proposal to collapse E/M codes for two years to 2021; this delay gives physicians of different perspectives the opportunity to come together, through the RUC/CPT Workgroup, and work toward developing a solution and a path forward in payment reform.”

Dr. Hruza noted that the AADA worked closely with the American Medical Association and other medical specialty groups to convey their concerns to CMS about the proposed rule, and that they look forward to working with policymakers on further refinements.

The final rule released is much different than the one proposed, which shows that CMS heeded concerns by physicians and took time to craft a more realistic fee schedule, said Orly Avitzur, MD, chair of the American Academy of Neurology’s Medical Economics and Management Committee. The proposed collapsed E/M levels would have likely led to shorter visit times, negatively impacting the doctor-patient relationship and patient care, she said.

“Overall, the American Academy of Neurology was extremely pleased that CMS made several reversals to the proposed rule that indicated that they really listened to our concerns and tried to address them,” Dr. Avitzur said in an interview. “We are very pleased they are giving us an additional 2 years to help us and other stakeholders to give them feedback about how to refine their decision to collapse levels 2, 3, and 4 codes.”

As part of its final rule, CMS moved forward with several other changes to coding and documentation, including eliminating the need to document the medical necessity of a home visit in lieu of an office visit, and allowing physicians to skip documentation of changes since a prior patient visit when relevant information is already contained in the record.

Additionally, the final rule clarifies that for E/M office/outpatient visits physicians do not need to re-enter information on the patient’s chief complaint and history that has already been entered by ancillary staff or the patient. The physician may just indicate in the medical record that he or she has reviewed and verified the information.

 

In a statement, CMS administrator Seema Verma said the final rule cements dramatic improvements for clinicians and patients and reflects extensive input from the medical community.

“Addressing clinician burnout is critical to keeping doctors in the workforce to meet the growing needs of America’s seniors,” Ms. Verma said in the statement. “[The] rule offers immediate relief from onerous requirements that contribute to burnout in the medical profession and detract from patient care. It also delays even more significant changes to give clinicians the time they need for implementation and provides time for us to continue to work with the medical community on this effort.”

sndr/istockphoto.com

With physicians facing excessive documentation requirements in their practices, it is a relief to see that the administration not only understands the problem of regulatory burden but is taking concrete steps to address it, said Barbara L. McAneny, MD, president of the American Medical Association.

“Patients are likely to see the effect as their physicians will have more time to spend with them and be able to more quickly locate relevant information in medical records,” Dr. McAneny said in a statement. “Implementation of these policies will streamline documentation requirements, reducing paperwork burdens that interfere with a meaningful patient-physician relationship.”

CMS finalized a number of proposals to pay doctors separately for communication technology services. This includes HCPCS code G2012 for brief communication technology-based services, such as virtual check-ins and HCPCS code G2010 for remote evaluation of a recorded video and/or images submitted by an established patient, also known as store and forward.

Additionally, CMS will pay separately for new codes that describe chronic care remote physiologic monitoring (CPT codes 99453, 99454, and 99457) and interprofessional Internet consultation (CPT codes 99451, 99452, 99446, 99447, 99448, and 99449). Also new to the list of reimbursable telehealth services are HCPCS codes G0513 and G0514 for prolonged preventive services.

Telehealth physicians who treat opioid use disorder received more flexibility under the CMS 2019 fee schedule through the agency’s removal of originating site geographic requirements. CMS will now allow a patient’s home to be an originating site for telehealth services for substance use disorder treatment or co-occurring mental health disorder. The agency is also accepting comments on a new Medicare benefit category for opioid use disorder treatment furnished by opioid treatment programs under Part B beginning on or after Jan. 1, 2020.

CMS also approved updates to its Medicare Shared Savings Program, including finalizing time-sensitive program policy changes for currently participating Accountable Care Organizations (ACOs). These changes include:

 

• A voluntary 6-month extension for existing ACOs whose participation agreements expire on Dec. 31, 2018, and the methodology for determining financial and quality performance for the 6-month performance year from Jan. 1 to June 30, 2019.
• Revising the definition of primary care services used in beneficiary assignment.
• Providing relief for ACOs and their clinicians impacted by extreme and uncontrollable circumstances in 2018 and subsequent years.

 

After a torrent of criticism from the physician community, the Centers for Medicare & Medicaid Services has delayed its proposed collapsing of evaluation and management (E/M) codes into single payments.

The agency’s final 2019 Physician Fee Schedule, announced Nov. 1, rescinds a proposal that would have blended payments for new and established patients for office/outpatient E/M levels 2 through 5 into single payments. Instead, the agency will continue to hear perspective on the proposal with plans to collapse E/M code levels 2 through 4 into single payments beginning in 2021, while maintaining level 5.

CMS also pulled back its proposal to apply a multiple procedure payment reduction to E/M visits furnished on the same day as a procedure. Payment rates for the less expensive of the two will be maintained, rather than cut in half as initially proposed.

The American Academy of Dermatology Association (AADA) expressed appreciation that CMS took feedback from the physician community seriously and that the agency took steps to eliminate some of its proposals.

“The AADA appreciates the effort and willingness of key decision makers at CMS, at HHS, and on Capitol Hill to hear the concerns of dermatologists and other physicians, and to take them into consideration in developing this final rule,” George J. Hruza, MD, president-elect of the AADA said in an interview. “We appreciate that CMS decided against moving forward with the proposal to make aggressive changes to payment associated with modifier 25 – when an office visit and one or more procedures are provided to a patient on the same day. We are also pleased that CMS made the decision to delay its larger proposal to collapse E/M codes for two years to 2021; this delay gives physicians of different perspectives the opportunity to come together, through the RUC/CPT Workgroup, and work toward developing a solution and a path forward in payment reform.”

Dr. Hruza noted that the AADA worked closely with the American Medical Association and other medical specialty groups to convey their concerns to CMS about the proposed rule, and that they look forward to working with policymakers on further refinements.

The final rule released is much different than the one proposed, which shows that CMS heeded concerns by physicians and took time to craft a more realistic fee schedule, said Orly Avitzur, MD, chair of the American Academy of Neurology’s Medical Economics and Management Committee. The proposed collapsed E/M levels would have likely led to shorter visit times, negatively impacting the doctor-patient relationship and patient care, she said.

“Overall, the American Academy of Neurology was extremely pleased that CMS made several reversals to the proposed rule that indicated that they really listened to our concerns and tried to address them,” Dr. Avitzur said in an interview. “We are very pleased they are giving us an additional 2 years to help us and other stakeholders to give them feedback about how to refine their decision to collapse levels 2, 3, and 4 codes.”

As part of its final rule, CMS moved forward with several other changes to coding and documentation, including eliminating the need to document the medical necessity of a home visit in lieu of an office visit, and allowing physicians to skip documentation of changes since a prior patient visit when relevant information is already contained in the record.

Additionally, the final rule clarifies that for E/M office/outpatient visits physicians do not need to re-enter information on the patient’s chief complaint and history that has already been entered by ancillary staff or the patient. The physician may just indicate in the medical record that he or she has reviewed and verified the information.

 

In a statement, CMS administrator Seema Verma said the final rule cements dramatic improvements for clinicians and patients and reflects extensive input from the medical community.

“Addressing clinician burnout is critical to keeping doctors in the workforce to meet the growing needs of America’s seniors,” Ms. Verma said in the statement. “[The] rule offers immediate relief from onerous requirements that contribute to burnout in the medical profession and detract from patient care. It also delays even more significant changes to give clinicians the time they need for implementation and provides time for us to continue to work with the medical community on this effort.”

sndr/istockphoto.com

With physicians facing excessive documentation requirements in their practices, it is a relief to see that the administration not only understands the problem of regulatory burden but is taking concrete steps to address it, said Barbara L. McAneny, MD, president of the American Medical Association.

“Patients are likely to see the effect as their physicians will have more time to spend with them and be able to more quickly locate relevant information in medical records,” Dr. McAneny said in a statement. “Implementation of these policies will streamline documentation requirements, reducing paperwork burdens that interfere with a meaningful patient-physician relationship.”

CMS finalized a number of proposals to pay doctors separately for communication technology services. This includes HCPCS code G2012 for brief communication technology-based services, such as virtual check-ins and HCPCS code G2010 for remote evaluation of a recorded video and/or images submitted by an established patient, also known as store and forward.

Additionally, CMS will pay separately for new codes that describe chronic care remote physiologic monitoring (CPT codes 99453, 99454, and 99457) and interprofessional Internet consultation (CPT codes 99451, 99452, 99446, 99447, 99448, and 99449). Also new to the list of reimbursable telehealth services are HCPCS codes G0513 and G0514 for prolonged preventive services.

Telehealth physicians who treat opioid use disorder received more flexibility under the CMS 2019 fee schedule through the agency’s removal of originating site geographic requirements. CMS will now allow a patient’s home to be an originating site for telehealth services for substance use disorder treatment or co-occurring mental health disorder. The agency is also accepting comments on a new Medicare benefit category for opioid use disorder treatment furnished by opioid treatment programs under Part B beginning on or after Jan. 1, 2020.

CMS also approved updates to its Medicare Shared Savings Program, including finalizing time-sensitive program policy changes for currently participating Accountable Care Organizations (ACOs). These changes include:

 

• A voluntary 6-month extension for existing ACOs whose participation agreements expire on Dec. 31, 2018, and the methodology for determining financial and quality performance for the 6-month performance year from Jan. 1 to June 30, 2019.
• Revising the definition of primary care services used in beneficiary assignment.
• Providing relief for ACOs and their clinicians impacted by extreme and uncontrollable circumstances in 2018 and subsequent years.

 

After a torrent of criticism from the physician community, the Centers for Medicare & Medicaid Services has delayed its proposed collapsing of evaluation and management (E/M) codes into single payments.

The agency’s final 2019 Physician Fee Schedule, announced Nov. 1, rescinds a proposal that would have blended payments for new and established patients for office/outpatient E/M levels 2 through 5 into single payments. Instead, the agency will continue to hear perspective on the proposal with plans to collapse E/M code levels 2 through 4 into single payments beginning in 2021, while maintaining level 5.

CMS also pulled back its proposal to apply a multiple procedure payment reduction to E/M visits furnished on the same day as a procedure. Payment rates for the less expensive of the two will be maintained, rather than cut in half as initially proposed.

The American Academy of Dermatology Association (AADA) expressed appreciation that CMS took feedback from the physician community seriously and that the agency took steps to eliminate some of its proposals.

“The AADA appreciates the effort and willingness of key decision makers at CMS, at HHS, and on Capitol Hill to hear the concerns of dermatologists and other physicians, and to take them into consideration in developing this final rule,” George J. Hruza, MD, president-elect of the AADA said in an interview. “We appreciate that CMS decided against moving forward with the proposal to make aggressive changes to payment associated with modifier 25 – when an office visit and one or more procedures are provided to a patient on the same day. We are also pleased that CMS made the decision to delay its larger proposal to collapse E/M codes for two years to 2021; this delay gives physicians of different perspectives the opportunity to come together, through the RUC/CPT Workgroup, and work toward developing a solution and a path forward in payment reform.”

Dr. Hruza noted that the AADA worked closely with the American Medical Association and other medical specialty groups to convey their concerns to CMS about the proposed rule, and that they look forward to working with policymakers on further refinements.

The final rule released is much different than the one proposed, which shows that CMS heeded concerns by physicians and took time to craft a more realistic fee schedule, said Orly Avitzur, MD, chair of the American Academy of Neurology’s Medical Economics and Management Committee. The proposed collapsed E/M levels would have likely led to shorter visit times, negatively impacting the doctor-patient relationship and patient care, she said.

“Overall, the American Academy of Neurology was extremely pleased that CMS made several reversals to the proposed rule that indicated that they really listened to our concerns and tried to address them,” Dr. Avitzur said in an interview. “We are very pleased they are giving us an additional 2 years to help us and other stakeholders to give them feedback about how to refine their decision to collapse levels 2, 3, and 4 codes.”

As part of its final rule, CMS moved forward with several other changes to coding and documentation, including eliminating the need to document the medical necessity of a home visit in lieu of an office visit, and allowing physicians to skip documentation of changes since a prior patient visit when relevant information is already contained in the record.

Additionally, the final rule clarifies that for E/M office/outpatient visits physicians do not need to re-enter information on the patient’s chief complaint and history that has already been entered by ancillary staff or the patient. The physician may just indicate in the medical record that he or she has reviewed and verified the information.

 

In a statement, CMS administrator Seema Verma said the final rule cements dramatic improvements for clinicians and patients and reflects extensive input from the medical community.

“Addressing clinician burnout is critical to keeping doctors in the workforce to meet the growing needs of America’s seniors,” Ms. Verma said in the statement. “[The] rule offers immediate relief from onerous requirements that contribute to burnout in the medical profession and detract from patient care. It also delays even more significant changes to give clinicians the time they need for implementation and provides time for us to continue to work with the medical community on this effort.”

sndr/istockphoto.com

With physicians facing excessive documentation requirements in their practices, it is a relief to see that the administration not only understands the problem of regulatory burden but is taking concrete steps to address it, said Barbara L. McAneny, MD, president of the American Medical Association.

“Patients are likely to see the effect as their physicians will have more time to spend with them and be able to more quickly locate relevant information in medical records,” Dr. McAneny said in a statement. “Implementation of these policies will streamline documentation requirements, reducing paperwork burdens that interfere with a meaningful patient-physician relationship.”

CMS finalized a number of proposals to pay doctors separately for communication technology services. This includes HCPCS code G2012 for brief communication technology-based services, such as virtual check-ins and HCPCS code G2010 for remote evaluation of a recorded video and/or images submitted by an established patient, also known as store and forward.

Additionally, CMS will pay separately for new codes that describe chronic care remote physiologic monitoring (CPT codes 99453, 99454, and 99457) and interprofessional Internet consultation (CPT codes 99451, 99452, 99446, 99447, 99448, and 99449). Also new to the list of reimbursable telehealth services are HCPCS codes G0513 and G0514 for prolonged preventive services.

Telehealth physicians who treat opioid use disorder received more flexibility under the CMS 2019 fee schedule through the agency’s removal of originating site geographic requirements. CMS will now allow a patient’s home to be an originating site for telehealth services for substance use disorder treatment or co-occurring mental health disorder. The agency is also accepting comments on a new Medicare benefit category for opioid use disorder treatment furnished by opioid treatment programs under Part B beginning on or after Jan. 1, 2020.

CMS also approved updates to its Medicare Shared Savings Program, including finalizing time-sensitive program policy changes for currently participating Accountable Care Organizations (ACOs). These changes include:

 

• A voluntary 6-month extension for existing ACOs whose participation agreements expire on Dec. 31, 2018, and the methodology for determining financial and quality performance for the 6-month performance year from Jan. 1 to June 30, 2019.
• Revising the definition of primary care services used in beneficiary assignment.
• Providing relief for ACOs and their clinicians impacted by extreme and uncontrollable circumstances in 2018 and subsequent years.