Changes to the 2019 PFS include the following:

  • Elimination of the requirement to document the medical necessity of a home visit in lieu of an office visit.
  • For established patients, when relevant information is already in the medical record, practitioners can focus documentation on what has changed since the last visit. Practitioners don’t need to re-enter the defined list of required elements if there so long as they have reviewed and updated the previous information as needed.
  • Practitioners need not re-enter information on the patient’s chief complaint and history that has already been entered by ancillary staff or the patient.
  • Removal of the potentially duplicative requirements for notations in medical records that may have previously been included by residents or other members of the medical team for E/M visits furnished by teaching physicians.

The final 2019 PFS rule also adds payments for some telemedicine services, as follows:

  • Brief communication technology-based service, e.g. virtual check-in (HCPCS code G2012)
  • Remove evaluation of recorded video and/or images submitted by an established patient (HCPCS code G2010).

According to CMS, practitioners could be separately paid for the brief communication technology-based service when the patient checks in via phone or other telecommunication device to decide whether an office visit or service is needed. Similarly, the remote evaluation of video or images submitted by an established patient would allow payment for reviewing the information to determine the necessity of an office visit.

One proposal that did not make it in the 2019 final rule involved the collapsing of E/M codes. CMS proposed paying a single rate for E/M office/outpatient visits with levels two through four while maintaining the payment rate for level five, among other changes. These E/M changes have been deferred to 2021, but the Medical Group Management Association (MGMA) says the proposal needs more refining.

“We welcome CMS’s deferral and revision of the collapsed E/M codes to 2021, but there’s more work to be done,” MGMA said in a statement. “Blending payments rates in 2021 won’t necessarily reduce burden, especially with CMS’ newly required add-on codes. MGMA will continue to examine the rule, leverage feedback from members, and work with CMS to create meaningful burden reduction for physician practices across the country.”

Lopez said the ACP has reservations about paying level four visits, the second most complex visit, at the same amount as levels two and three. “Internists appreciate CMS’ decision not to finalize changes in payments for evaluation and management services until 2021. We are hopeful that the additional two calendar years leave time for physicians and other health care stakeholders to work together with regulators to develop and test alternatives that preserve higher payment for more complex, cognitive care,” she said.

The American Medical Association also supported with the delay. “The AMA also is grateful that the Administration is not moving forward in 2019 with the payment collapse of E/M codes,” said AMA President Barbara L. McAneny, MD, in a statement. “A two-year window for implementation of the proposal will give the AMA-convened workgroup—comprised of physicians and other health professionals —time to make recommendations on this complicated topic.”

Overall, William S. Mayo, DO, president of the American Osteopathic Association, said he is pleased CMS listened to commenters’ feedback. “The AOA is grateful that CMS heeded the concerns expressed by practicing physicians about the proposed rule and looks forward to advancing the dialogue on how physician payment policy can be modified for the betterment of both physician practice and the patients we care for,” Mayo said in a statement.

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