CMS Delays Dramatic Office-Visit Coding Changes Until 2021
By Joey Berlin

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Following advocacy by the Texas Medical Association and much of organized medicine, the Centers for Medicare & Medicaid Services (CMS) has delayed its proposal to dramatically overhaul evaluation and management (E&M) coding for physician services, a proposal that TMA warned would make treating Medicare patients “even more challenging.”

CMS released its final 2019 physician fee schedule Thursday afternoon, saying in a release that it was delaying implementation of E&M coding changes until 2021 to “allow for continued stakeholder engagement.” 

That’s an indication CMS listened to the objections of TMA and others. The CMS proposal, released in July, sought to collapse the five levels of outpatient-visit payments down to just two levels, with one payment for level 1 visits and the same flat payment rate applying to levels 2-5. 

In comments to CMS, TMA warned of ugly consequences if that payment scheme became reality, telling the agency that it would remove incentives for physicians to care for patients with complex and complicated conditions. TMA’s comments, which offered 75 distinct recommendations for improvements, called the proposal “neither accurate, fair, nor adequate.”

But for now, it won’t happen, as the final rule maintains the current five-level payment structure for 2019 and 2020. Meanwhile, CMS says “several documentation policies to provide immediate burden reduction” are going into effect with the 2019 fee schedule.

CMS also announced it’s not implementing another proposal that would have reduced payments when E&M visits occur on the same day as procedures. TMA also strongly objected to that proposal.

The final rule also contains changes to Medicare’s Quality Payment Program. Among those changes: Adding a new, third criterion — number of covered professional services —  to the criteria that determine whether physicians fall under the low-volume threshold that would exempt them from the Merit-Based Incentive Payment System (MIPS).

TMA is hard at work analyzing the more-than-2,300-page final rule. We’ll provide more information on what’s in the rule in the coming weeks. In the meantime, you can view a fact sheet on the physician fee schedule portion here, and a fact sheet on the QPP parts of the rule here


Last Updated On

November 02, 2018

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Joey Berlin

Associate Editor

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Joey Berlin is associate editor of Texas Medicine. His previous work includes stints as a reporter and editor for various newspapers and publishing companies, and he’s covered everything from hard news to sports to workers’ compensation. Joey grew up in the Kansas City area and attended the University of Kansas. He lives in Austin.

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