CMS has just released its Final Rule on the 2019 Medicare Physician Fee Schedule, and for the moment the dust has settled on all the discussions, debates, and deliberations regarding evaluation and management (E/M) levels and documentation. It contains a picture – albeit one that is still a fuzzy work-in-progress – of what CMS may have in mind for the future of coding patient encounters.
Here are the five main takeaways from the 2,378-page document that E/M coders everywhere should know:
Initially, CMS was proposing a two-tiered system for E/M visits that would leave the current level 1 as it is and blend payments for current levels 2-5 into another, second level. After much stakeholder input, however, CMS has changed its mind and has now put on the table a proposal for a three-tiered system that would blend current levels 2-4 while leaving levels 1 and 5 intact.
If this happens at all, it won’t be until 2021. In the interim, CMS will continue its “discussions with the public … to potentially further refine … policies, through future notice and comment rulemaking,” according to the Final Rule.
For CY 2019 and 2020, you’ll continue to use either the 1995 or 1997 E/M guidelines (history, exam, and/or MDM) to document E/M office/outpatient visits, or you’ll use the duration of the visit to select the appropriate E/M visit level when counseling and/or coordination of care accounts for more than 50 percent of the face-to-face physician/patient encounter.
If CMS does implement the three-tier proposal, you may have to use “a minimum supporting documentation standard associated with level-2 visits” for current “E/M office/outpatient level 2 through 4 visits” and “for level-5 visits, documentation requirements applicable to a level 5 visit or the current definition of level 5 MDM.”
You may also have the choice of using current 1995 or 1997 documentation guidelines (history, exam, and MDM), MDM alone, or time alone (using a definition of time that has yet to be determined) to document the E/M level. But, again, discussions between CMS and its stakeholders will continue on this front.
Effective CY 2019, CMS is following through on its promise to help you eliminate redundant data recording. For now, this means allowing practitioners to “focus their documentation on what has changed since the last visit, or on pertinent items that have not changed” and “not re-record the defined list of required elements” or “re-enter in the medical record information on the patient’s chief complaint and history.”
But CMS adds two caveats you should also note. First, if you do go this route, there must be “evidence that the practitioner reviewed the previous information and updated it as needed” in the record, even if that information “has already been entered by ancillary staff or the beneficiary.” And second, if you don’t want to do this, you have the option to continue your current practices as “the policy … is optional for practitioners, and they may choose to continue the current process of entering, re-entering and bringing forward information.”
What This All Means for Your Bottom Line
Well, it appears your revenue won’t be going down next year as everyone feared when CMS first floated the blended E/M payment proposal. In fact, CMS’s elimination of the requirement to re-record required patient documentation should reduce your administrative burden and give you and your provider more time to do more productive work. That could well mean more money in your wallet in the new year, and that’s something to look forward to as we head into 2019.
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