By: Lorna Simons, CPC
Medco Consultants, Inc
E/M Changes Proposed in the Revisions to Payment Policies under the Medicare Physician Fee Schedule, Quality Payment Program and Other Revisions to Part B for CY 2019
There are a lot of concerning changes proposed to Outpatient Evaluation and Management (E/M) services currently being assessed by Medicare. While a long-awaited change is currently being considered for the documentation guidelines, the Revisions to Payment Policies under the Medicare Physician Fee Schedule, Quality Payment Program and Other Revisions to Part B for CY 2019 is also considering flat rate fees for all outpatient new and established evaluation and management services. Additionally, proposed changes are being considered for the creation of separate codes to report Podiatric E/M services. These changes are all linked.
As per the proposed rules: “the current set of 10 CPT codes for new and established office-based and outpatient E/M visits and their respective payment rates no longer appropriately reflect the complete range of services and resource costs associated with furnishing E/M services to all patients across the different physician specialties, and that documenting these services using the current guidelines has become burdensome and out of step with the current practice of medicine…To alleviate the effects and mitigate the burden associated with continued use of the outdated CPT code set, we are proposing to simplify the office-based and outpatient E/M payment rates and documentation requirements, and create new add-on codes to better capture the differential resources involved in furnishing certain types of E/M visits.”(p136-137)
The proposed rates are as follows:
The specialties that will be most negatively affected by these changes are Rheumatology, Neurology, Hematology/Oncology and Endocrinology.
In regard to podiatry services, the proposed rules indicate that a majority of podiatric E/M services are level 2 or 3 services and that the consolidation payment rates for level 2-5 services does not accurately reflect the resources used to perform an E/M service in the podiatric setting. If the specialty were to be included podiatry would receive the greatest benefit out of all the specialties, approximately a 12% increase in payment. Rather than include the specialty in this consolidation of E/M payment, CMS is proposing the creation of two (2) new HCPCS codes: GPD0X for New patients and GPD1X for Established patients.
The proposed regulations were published on July 27, 2018. Luckily these are just proposed changes and affected providers are still currently able to comment on these proposals until September 10, 2018.
CMS- 1693-P, p 132- 145
How to Participate in the Rulemaking Process