Online Publication Date:
24 Jul 2018
Big changes in CMS Evaluation and Management (E&M) coding

Medicare has proposed changes to the payment rules for dialysis care and physician reimbursement for calendar year 2019. While several proposed changes are positive, one proposed adjustment to the Evaluation and Management (E&M) coding reimbursement structure has created serious concern and will be a priority in the American Society of Nephrology’s (ASN) comments to Medicare.
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David White
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Medicare has proposed changes to the payment rules for dialysis care and physician reimbursement for calendar year 2019. While several proposed changes are positive, one proposed adjustment to the Evaluation and Management (E&M) coding reimbursement structure has created serious concern and will be a priority in the American Society of Nephrology’s (ASN) comments to Medicare.

Specifically, the proposed rules are for the End-Stage Renal Disease (ESRD) program, the Physician Fee Schedule (PFS), and the Quality Payment Program (QPP). For the first time, CMS has combined the proposed changes for the PFS and the QPP into one combined proposed rule .

The ASN Quality Committee met for a day-long, in-person session in July at the ASN offices in Washington, DC, to discuss the content of the proposed changes in the proposed rules – especially the recommendations to change E&M coding reimbursement.

Highlights of the proposed changes are as follows:

Physician Fee Schedule/Quality Payment Program

  • Reducing Evaluation and Management (E&M) coding documentation
  • Creating a compressed single payment for E&M levels 2-5 (one for new patients and one for established patients), which is of particular concern to ASN
  • Allowing the scoring methodology for the End-Stage Renal Disease (ESRD) Quality Incentive Program (QIP) to be used for clinicians who spend the majority of their time in the dialysis facility
  • Creating new telehealth opportunities


ESRD PPS/QIP

  • Changing, expanding Transitional Drug Add-on Payment Adjustment (TDAPA)
  • Removing some quality measures and adding transplant metrics
  • Emphasizing innovation


The ASN Quality Committee, chaired by Daniel E. Weiner, MD, FASN, and staff are reviewing the measures in greater depth and with other groups in the kidney community. They will prepare recommendations for comments on the proposed changes for the ASN Council to review and approve.  Final comment letters must be submitted to CMS by September 10, 2018, but ASN intends to submit comments earlier to ensure that CMS has the opportunity to review them thoroughly and ensure the nephrologist perspective is heard. Please feel free to send comments to policy@asn-online.org .

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