News: CMS delays E/M changes to 2021, modifies documentation requirements

CDI Strategies - Volume 12, Issue 53

CMS hit the brakes on making imminent changes to the oft-used evaluation and management (E/M) code set that’s tied to billions of dollars in medical practice revenue, Revenue Cycle Advisor reported. Streamlined payment rates are off the table for 2019, as are vast documentation revisions, according to the 2,378-page final 2019 Medicare physician fee schedule released November 1.

That doesn’t mean changes aren’t coming January 1, or beyond. CMS plans to weave a number of smaller updates into the E/M payment and documentation picture in 2019 and will implement a broader array of changes in 2021, including a single-rate payment structure for certain established and new patient codes.

However, CMS backed off on many of its ire-inducing proposals that would have drastically reshaped how it pays for and assesses the accuracy of E/M services, according to Revenue Cycle Advisor.

“Commenters largely objected to our proposal to eliminate payment differences for office/outpatient E/M visit levels 2 through 5 based on the level of visit complexity,” CMS says in the final rule. Many commenters said they would experience pay cuts and generally let the agency know that the “aggressive” launch date that CMS proposed for January 1, 2019, was far too fast.

Instead, in 2019 and 2020, CMS will maintain separate payments for each distinct E/M code. Practices also will continue to use the current 1995 and 1997 E/M documentation guidelines.

However, CMS plans to move forward with  a few meaningful changes  starting January 1, including:

  • For E/M visits, providers will not be required to re-enter information about the patient’s chief complaint and history that a staff member has already entered. Instead, the provider can indicate in the medical record that the information has been “reviewed and verified.”
  • For established office visits, providers can focus their documentation on changes since the last visit and “need not re-record the defined list of required elements if there is evidence” that the provider has already done so.
  • For home visits, providers will no longer be required to prove explicit medical necessity when reporting the range of codes 99341-99350.

Despite a two-year slowdown, CMS anticipates going full-throttle into 2021 with a series of major revisions to E/M coding, payments, and documentation requirements, Revenue Cycle Advisor reported.

The agency plans to rekindle its approach to single-rate payments, although it will excise the highest-level codes from the flattened fees. Instead, the pay rates will bundle levels 2 through 4 codes into a to-be-determined payment amount. The level 5 codes will be left alone “to better account for the care and needs of complex patients,” CMS states. A fact sheet for E/M payment amounts shows what payments might look like with and without various add-on codes.

Documentation changes also continue. Starting in 2021, practices will be able to opt for medical decision-making or time as the key documentation requirement when reporting E/M office codes. CMS plans to adopt a minimum documentation standard for the levels 2 through 4 codes.

The add-on codes that CMS had proposed also are set to return in 2021; however, they’ll be limited to levels 2 through 4. And practices will be able to tap into an “extended visit” code to account for high-duration encounters that correspond to a level 2 through 4 visit.

Though they’ve delayed some of their original proposals, CMS believes the 2019 changes will provide “immediate burden reduction,” something it has emphasized in recent rulemaking periods.

Editor’s note: This article originally appeared in Revenue Cycle Advisor. To read the CMS fact sheet on these changes, click here. To read about all the proposed changes, click here. To read about CMS’ ongoing task of reducing administrative burden, click here.

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