Thursday afternoon, November 1, Medicare released the final Physician Fee Schedule (PFS) rule containing some revisions to evaluation and management (E&M) codes in terms of documentation requirements but no changes in reimbursement levels for the next two years – but year three is another matter.
The desire to reduce the documentation burden in E&M coding led CMS in July to propose a system that collapsed levels 2-5 of E&M into one reimbursement payment. This move had negative implications for nephrologists and pretty much any physician practicing cognitive care with complex patients. So, where did we end up and what do you need to know?
Thursday afternoon, November 1, Medicare released the final Physician Fee Schedule (PFS) rule containing some revisions to evaluation and management (E&M) codes in terms of documentation requirements but no changes in reimbursement levels for the next two years – but year three is another matter.
The desire to reduce the documentation burden in E&M coding led CMS in July to propose a system that collapsed levels 2-5 of E&M into one reimbursement payment. This move had negative implications for nephrologists and pretty much any physician practicing cognitive care with complex patients. So, where did we end up and what do you need to know?
For CY 2019 and CY 2020, CMS will continue to allow you to use the current coding and payment structure for E&M office/outpatient visits and you should continue to use either the 1995 or 1997 E&M documentation guidelines. For CY 2019 and beyond, most of you will be pleased to see that CMS is:
- Changing the required documentation of the patient’s history to focus only on the interval history since the previous visit
- Eliminating the requirement for physicians to re-document information that has already been documented in the patient’s record by practice staff or by the patient
- Removing the need to justify providing a home visit instead of an office visit
- Declining to move forward on a proposal to reduce payment for office visits when performed on the same day as another service.
Starting in the CY 2021, CMS plans on:
- Paying a single rate for E&M office/outpatient visit levels 2-4 for all patients while maintaining level 5
- Permitting you to choose to document E&M office/outpatient level 2-5 visits using medical decision-making or time instead of applying the current E&M documentation guidelines
After omitting nephrology from the list of specialties dealing with complex patients that could use an add-on code for complexity in the proposed rule, CMS wrote in the final rule that “We also agree with commenters that the code descriptor omitted several specialties that provide this type of visit, such as nephrology, psychiatry, pulmonology, infectious disease, and hospice and palliative care medicine… As discussed previously, appropriate reporting of the specialty care resource add-on code should be apparent based on the nature of the clinical issues addressed at the E/M visit, and not limited by the practitioner’s specialty.”
ASN Policy and Advocacy will continue to analyze this rule further and will be providing you additional information in December’s Kidney News.
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