CMS' 2019 Proposed Medicare Fee Schedule
Written by Editor   
Wednesday, July 18, 2018 06:09 PM

With great fanfare, officials at the Centers for Medicare & Medicaid Services (CMS) announced a number of proposed initiatives in the 2019 Medicare physician fee schedule.  "I spent part of the last year traveling the country and visiting clinicians in different care settings," CMS administrator Seema Verma said. "One thing we heard time and time again is that time spent on paperwork is time away from patients .... It became clear to me that if we were going to be serious about improving quality and access for patients, we have to improve the lives of providers on the front lines."

One example of this push is several proposed documentation changes aimed at cutting the burden on physicians who provide evaluation and management (E/M) services. These include giving providers the following options:
  • Documenting office/outpatient E/M visits using medical decision-making or time instead of applying the current 1995 or 1997 E/M documentation guidelines
  • Using time as the governing factor in selecting visit level and documenting the E/M visit, even if counseling or care coordination dominates the visit
  • Focusing documentation on what has changed since the last visit or on pertinent items that have not changed, rather than re-documenting information, provided the physician reviews and updates the previous information
  • Reviewing and verifying certain information in the medical record that is entered by ancillary staff or the beneficiary, rather than re-entering it

CMS is also proposing to streamline the E/M coding system itself by having "new, single blended payment rates for new and established patients for office/outpatient E/M level 2 through 5 visits and a series of add-on codes to reflect resources involved in furnishing primary care and non-procedural specialty generally recognized services," the agency said in a fact sheet posted on its website.

This change includes a "minimum documentation standard" for a level 2 visit "where Medicare would require information to support a level 2 CPT visit code for history, exam and/or medical decision-making in cases where practitioners choose to use the current framework, or, as proposed, medical decision-making to document E/M level 2 through 5 visits," CMS said.

"In cases where practitioners choose to use time to document E/M visits, we propose to require practitioners to document the medical necessity of the visit and show the total amount of time spent by the billing practitioner face-to-face with the patient," the fact sheet continued. Although physicians might want to include additional information for clinical or legal reasons, "we would only require documentation to support the medical necessity of the visit and associated with the current level 2 CPT visit code."

The agency estimated that making these changes to E/M coding will save providers 51 hours per year, an amount that Verma said was "one of the most significant reductions in provider burden undertaken by any administration."

One area that Verma did not discuss was the overall percentage increase in the amount that Medicare was reimbursing physicians. Last year, Medicare increased overall payments to physicians by 0.41%. This year, payments will increase by $0.3 billion -- that includes a 0.25% increase as mandated in this year's Bipartisan Budget Act, minus 0.12 percentage points to account for some changes in relative value units.

The proposed rule also lists the fee schedule's final conversion factor -- the amount that Medicare's relative value units are multiplied by to arrive at a reimbursement for a particular service or procedure under Medicare's fee-for-service system. That figure is $36.05, up slightly from last year’s conversion factor of $35.99.