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Healthcare Leadership Team

EAlert: CMS Final Rule -- Be Heard on E/M Changes

In the Final Rule for 2019, CMS proposes to answer the call of providers to revise E/M coding & documentation for both new and established outpatient visits. The impact to your practice could be significant. The proposed changes not only restructure the documentation of services but also restructure the reimbursement to what essentially becomes a single tier payment for outpatient-office based E/M visits. To make things even more complicated, CMS proposes add-on codes to identify the amount of resources required to deliver your services.

First, the proposed payment for New Patient codes 99202-99205 is a flattened fee of $135 dollars and for Established Patient codes 99212 – 99215, $93 dollars. Level I visits (99201 and 99211) would be $24 & $44 dollars respectively.

The add-on codes are proposed to reimburse $5 to recognize additional resources for a primary care visit and $14 for “certain” non-procedural based care (this has not yet been defined). In addition, CMS proposes to create a payment reduction similar to a multi-surgery procedural reduction when an E/M visit is provided same-day as a procedure.
The changes to documentation requirements are said to reduce administrative burden and improve payment accuracy for E/M visits. The proposed documentation changes would allow practitioners to choose to:
  1. continue to document using the current 1995 or 1997 E/M documentation guidelines; 
  2. use medical decision-making (soliciting comment) or;
  3. use time
The minimum documentation standard would correlate to the current standard of a Level II E/M visit for history, exam and/or medical decision-making when providers choose to use the current documentation framework, (1995 or 1997 E/M Guidelines) OR; as proposed, based on medical decision-making to document E/M level 2 through 5 visits. Providers, who choose to use time to document E/M visits, would be required 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.

These changes could significantly affect your practice. Read the details of all Physician Fee Schedule proposed changes here:

Many providers and provider organizations have already commented and the comments are largely negative. The Proposed Rule comment period deadline is Sept 10, 2018. You have the opportunity to comment on these changes by clicking on the following link and following the steps to # of days, proposed rule and agency (CMS) until that date.

Don’t settle for changes that may be harmful to your practice sustainability - Be heard!
For more information, contact Stephanie Fiedler, Director, Revenue Advisory Services at Grassi Healthcare Advisors, LLC, at