Yesterday CMS released their CY 2019 physician fee schedule proposed rule, which includes major proposed changes to E&M coding. Below is my review of this component of their propose rule, including page references to the source in the federal register.
We all know E&M coding has it flaws, and 1995/1997 guidelines could not have accounted for changes in technology today, especially the EHR. Furthermore, many consider E&M guidelines as being too complex, ambiguous and incapable of meaningfully distinguishing between different code levels. For some time, physicians and other stakeholders have asked CMS to undergo extensive research to overhaul both the E&M documentation guidelines and the underlying coding structure. You would essentially blunt any potential benefit by updating one and not the other. Based on all of the feedback provided thus far, CMS begins their proposal by defining a number of trends which emerged from the feedback:
• Substantially different recommendations came in by specialty; any changes would have both clinical and financial specialty-specific impacts
• History and exam portions of the guidelines are most significantly outdated; they should be simplified or reduced, but not eliminated
• Medical decision making should be given more weight in determining visit level, but those specific guidelines should be updated as well
• Reduce E&M levels generally into three, such as low / medium / high, and also correlate these to time