Proposed Policy, Payment, and Quality Provisions Changes to the Medicare Physician Fee Schedule for Calendar Year 2019

In line with its commitment to the Patients Over Paperwork initiative, The Centers for Medicare & Medicaid Services (CMS) is committed to increasing the amount of time a provider spends with a patient by eliminating and/or streamlining some of the E/M documentation and coding requirements. Specifically, CMS proposes the following:

  • Providers may assign a level of service based on “time” or “decision making” rather than the traditional requirements mandated by the 1995 or 1997 E/M Documentation
    Guidelines.

    • Under this option, “time” is not driven by “counseling” or “coordination of care” (none even has to occur). Rather, the level is determined by the actual amount of time the physician spends with the patient for any service(s).
    • Providers may determine the level of service based upon the medical decision required to perform the service. To date, under this option, CMS does not mandate the use of criteria to determine the level of medical decision making but providers will likely rely on the criteria available in the 95 and 97 guidelines. If not, the provider must document the method/reason for the level assignment and be consistent in the use of the criteria. CMS and other regulators will want to see consistent application to justify levels of services upon reimbursement audits.
  • Streamline documentation of the exam and physical by allowing providers to “authenticate” information that hasn’t changed on a previous report or a report written by ancillary staff or the patient (after conducting a current patient examination and documentation review). Currently, the provider must re-write the documentation.
    • This will require focused documentation reviews to ensure current data is documented (signed and dated) and readily available (easy to locate) for continued patient care and coding.

For more information on E/M documentation, contact Linda Mancini at 781-272-8001.