News: CMS releases PFS, proposes changes to E/M documentation guidelines, payment decreases

Last week, CMS proposed major changes to the fiscal year (FY) 2019 Physician Fee Schedule (PFS) and the Quality Payment Program (QPP), some of which could change the Evaluation and Management (E/M) documentation requirements, the coding system for physician practices.

The proposals will “deliver on the pledge to put patients over paperwork by enabling doctors to spend more time with their patients,” according to CMS Administrator Seema Verma. “Physicians tell us they continue to struggle with excessive regulatory requirements and unnecessary paperwork that steal time from patient care.”

The proposals, if finalized, will simplify E/M payment in several ways, HealthLeaders Media reported, including:

• Rather than complying with documentation guidelines from the 1990s, providers would be able to choose to document E/M visits based on time spent with the patient or on their own medical decision-making.
• Providers would be allowed to use time as the primary factor in determining visit level, without regard to how much of that time was spent on counseling or coordinating care.
• Rather than having to re-document information from past visits, practitioners would have more options to simply review and update existing documentation.
• Physicians would be allowed to simply review and verify certain medical records that staff members or the patient entered into the EHR system.

In addition to the documentation requirement changes, the proposals would change the current five-tier E/M system into a one-tier system with blended payment rates for office and outpatient visits billed at the second through fifth levels, according to HealthLeaders Media.

This change could result in a negative payment adjustment for providers of 1%-2%, Verma wrote in a letter to physicians this week. “We believe that any small negative payment adjustments would be outweighed by the significant reduction in documentation burden,” she wrote.

CMS’s proposed changes to the QPP are also aimed at reducing burden, according to the agency’s release, as well as focusing on outcomes and promoting interoperability of EHRs. These proposals include:

• Removing the Merit-based Incentive Payment System (MIPS) process-based measures that clinicians have said are low-value or low-priority, in order to focus on meaningful measures that have greater impacts on health outcomes.
• Overhauling the MIPS “Promoting Interoperability” performance category to greater support EHR interoperability and patient access to their health information, as well as to align this performance category for clinicians with the proposed new Promoting Interoperability Program for hospitals.

“Enough is enough,” wrote Verma in her letter to physicians, referencing climbing levels of physician burnout. “CMS’s focus is on putting patients first, and that means protecting the doctor-patient relationship. We believe that you should be able to focus on delivering care to patients, not sitting in front of a computer screen.”  

Editor’s note: To read HealthLeaders Media’s coverage of these proposals, click here. To read the release from CMS, which includes Fact Sheets and comment instructions, click here. To read about Verma’s letter to physicians from EHRIntelligence, click here. Comments on the proposals are due by September 10.