As of Jan. 1, 2019, the Centers for Medicare & Medicaid Services (CMS) will implement several coding and documentation policies to provide immediate burden reduction to providers. The 2019 Medicare Physician Fee Schedule Final Rule (MPFS) released Nov. 1, 2018, by the CMS contained significant changes to the Medicare Part B coding and documentation policies to deliver on its pledge to prioritize patients over paperwork.
The ACR appreciates the CMS’ effort to work with the medical community and not move forward with its original proposal to collapse the payment of the evaluation and management (E/M) codes in 2019. As you know, the ACR was a leader among the specialties on the E/M consolidation issue; our efforts included helping facilitate a large provider/patient group letter and two Congressional letters that expressed concerns to the Trump administration, so we are especially glad to see the CMS seems to have listened. With the two-year window before implementing the January 2021 proposal to revisit collapsing the E/M codes, the ACR advocacy team will continue to work with our coalition partners to make recommendations on this complicated topic.
Key Medicare E/M Changes
For 2019 and 2020, the CMS has indicated it will continue to use the current coding rules and payment structure for E/M office/outpatient visits, so providers can continue to use either the 1995 or 1997 versions of the E/M guidelines to document new or established patient visits billed to Medicare. Below are the key changes rheumatology practices should take into consideration for documenting Medicare E/M services:
- For established patient office/outpatient visits, focus documentation of history and exam on what has changed since the last visit or on pertinent items that have not changed, rather than redocumenting information. Providers will still need to review and update the previous information;
- Providers will not need to rerecord the defined list of elements if there is evidence the information was previously reviewed and updated as needed;
- For E/M office/outpatient visits for new and established patients, practitioners will not need to re-enter information in the medical record of the patient’s chief complaint and history that was previously entered by ancillary staff or beneficiary; and
- Providers can choose to continue using the 1995 or 1997 E/M guidelines if doing so meets their practice needs.
Removing redundancy in E/M documentation is a key win in the CMS’s final rule because this can be a duplication of work in most practices. Especially for established patients, documenting information in the provider’s note, particularly with regard to history and exam, that is already present in the medical record should not be required. Currently, both the 1995 and 1997 guidelines provide such flexibility for certain parts of the history for established patients, stating: A review of systems (ROS) and/or a pertinent past, family and/or social history (PFSH) obtained during an earlier encounter does not need to be rerecorded if there is evidence the physician reviewed and updated the previous information.
