Due to overwhelming stakeholder feedback — much of it negative — the Centers for Medicare & Medicaid Services (CMS) decided to stagger its overhaul of E/M documentation, coding, and payment policies over the course of two years, with only a handful of revisions for this year.
Are you clear on the 2019 Medicare Physician Fee Schedule (MPFS) final rule — and which E/M policy changes are now in effect?
Next year and continuing into 2020, practices should follow the 1995 or 1997 E/M documentation guidelines when reporting E/M office/outpatient visits they bill to Medicare. However, in the final rule, CMS does update some policies that have gone into effect on Jan. 1, 2019. Knowing both the current requirements and what’s new is critical.
Review these revised policies in the MPFS final rule for 2019:
1. Update home visit decision-making. Comments poured in from practitioners that they should be able to make the decision on whether to treat patients at home or in the office — without excessive documentation to prove the medical necessity for venue. CMS agreed and is nixing the proposed, more stringent documentation requirements. These services fall under CPT® codes 99341 to 99350, the MPFS noted.
2. Accept staff notes. Instead of re-entering “chief complaint and history” data that “ancillary staff” already updated, physicians can plow ahead with E/M office/outpatient visits for both established and new patients, suggested the MPFS fact sheet.
3. Focus on patient changes. Documenting new issues for established patients for office/outpatient visits is vital for quality care, and CMS will now allow providers to focus on that rather than information already in the medical record, especially if there’s evidence the physician reviewed the details, the agency said. “Practitioners should still review prior data, update as necessary, and indicate in the medical record that they have done so,” reminds the fact sheet.
4. Cut down on duplicates. The agency wants to simplify documentation for teaching physicians by removing “potentially duplicative requirements for notations,” particularly if residents or other medical staff have already uploaded their notes, the MPFS indicated.
Efforts to reduce regulatory burdens and simplify the documentation requirements for E/M visits will no doubt be welcomed by organizations. Even the small rollbacks in 2019 will make a difference for providers struggling with too much administrative work.
Plus — New & Revised Codes for Interprofessional Services
As CMS commits to expanding telehealth and virtual care, you now have some changes to interprofessional telephone/Internet services that were recently finalized in the CY 2019 MPFS.
Revisions: The revisions focus mainly on the inclusion of “electronic health record” into the descriptor. Moreover, according to the final rule, these previously bundled codes will now be paid separately, too. The CPT® codes are as follows:
New codes: Meanwhile, you can add the following two codes to your CPT® checklist that primarily focus on a written report and referral service:
Caution: The finalized policy will “require the patient’s verbal consent,” which must be “noted in the medical record for each interprofessional consultation service” code, CMS says. “Cost sharing will apply for these services,” too, and the codes are only an option for providers who “can bill Medicare independently for E/M services,” the final rule advises.
Anticipate E/M documentation and payment changes that will impact your practice with a look at the top six policy updates slated for 2021.
1. E/M single payment rate details revealed. The amount isn’t finalized, but you can expect a single payment rate for level 2 through 4 codes for E/M office/outpatient visits for your new and established patients. CPT® codes 99205 and 99215, however, will no longer fall under the single payment system as suggested before, but instead will remain steady “to better account for the care and needs of complex patients,” the agency stressed.
2. Clinicians can decide which documentation guideline to follow. Despite mixed feelings from the public on three documentation guideline choices, the agency pushed through the policy. In 2021, Medicare providers can use either the 1995 or 1997 documentation guidelines for E/M office/outpatient level 2 through 5 visits, or they can use medical decision-making (MDM) or time. It is important to mention that some “commenters noted such a policy would increase burden due to increased variation in how visits would be documented, and the need to restructure EHR templates to accommodate different options and decide which method was best for a given patient or practice,” said the final rule.
3. Minimum documentation standard outlined … sort of. Even though “many commentators did not support the proposal … to apply a minimum level 2 documentation standard,” CMS will be instituting it anyway in 2021. What this means is that when you perform a level 2 through 4 visit using MDM or the current standards, you’ll need to submit “information to support a level 2 E/M office/outpatient visit code for history, exam and/or medical decision-making,” the fact sheet noted.
4. Time is of the essence. According to the guidance, medical necessity must be clearly explained when time is used to document the E/M visit. Also, that documentation needs to specifically point out that it was the billing provider who was face-to-face with the patient for the claim to be accepted.
5. Add-on codes are coming. Those promised add-on codes that are supposed to bump up the single payment stats are set for release in 2021. The aforementioned codes will help explain “additional resources” but won’t be restricted by specialty, CMS said. “These codes would only be reportable with E/M office/outpatient level 2 through 4 visits, and their use generally would not impose new per-visit documentation requirements,” the fact sheet advised.
6. Extra-long visits receive a boost. For level 2 through 4 E/M visit codes, CMS will introduce a brand new “extended visit” code, the agency said. Practitioners will be able to use this code “regardless of the kind of care” furnished “or whether or not the medical complexity of the visit is the determining factor for the length of visit,” the final rule stated.
Contributing Editor: Kristin Webb-Hollering
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