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Proposed major changes in E&M codes

Wednesday, August 8, 2018   (0 Comments)
Posted by: DCMS
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The American Medical Association (AMA) has weighed in on the Proposed 2019 Physician Fee Schedule, specifically on the impact of the changes surrounding Evaluation and Management Codes. The changes theoretically are designed to reduce physician burden, but may also impact reimbursement.

Below is the AMA’s initial summary, and you can click here to access the impact of the proposed codes on your practice.



There are a number of positive elements in the 2019 Proposed Physician Fee Schedule Rule. These include:

·        A major reduction of the documentation burden for Evaluation & Management Office visit codes

·        New payments for physician services that are not part of a face to face office visit (virtual check-ins, remote consults of patient videos and photographs and online consultations with other physicians)

·        Continuation and expansion of a low volume threshold exception policy to exempt small practices from the Merit Incentive Payment System (MIPS)

·        A reduction in problematic measures in the Promoting  Interoperability provisions (formerly Meaningful Use and Advancing Care Information)


There are several areas were the AMA will be recommending clarifications, modifications and improvements.   These include:

·        Further reductions in quality measure requirements to reflect reductions in available quality measures

·        Simplifying the MIPS scoring framework to make it more clinically relevant and understandable for physicians

·        Testing and adoption of physician focused APMs


Concerns Regarding Impact of Proposed Evaluation & Management Coding Changes

In the 2019 Proposed Physician Fee Schedule Rule, the Centers for Medicare and Medicaid Services (CMS) included a proposal to reduce physician burden.  The proposal seeks to reduce documentation burden for physicians by modifying E/M services through collapsing codes and payment levels. 

The AMA’s attached analysis looks at the specific impact on separately reported office visits. This is the key difference between the percentage impacts included in the CMS Proposed Rule (click here for table 22), where the monetary redistribution of the E/M proposal was displayed as changes in total Medicare allowed charges by specialty. Further, the AMA summarized the specific E/M impact for each Medicare designated specialty with more than $1 million in office visit spending, while CMS displayed impacts with less specialty granularity (for example, hematology, medical oncology and hematology/oncology are rolled into hematology/oncology in Medicare impact tables, while the AMA shows the impacts on each individual specialty).  Like CMS, the AMA analysis does not include the proposed new add-on code GPRO1 (Prolonged evaluation and management or psychotherapy service(s) (beyond the typical service time of the primary procedure) in the office or other outpatient setting requiring direct patient contact beyond the usual service; 30 minutes) as the criteria for reporting the service are not yet determined and data on current time spent in direct contact beyond the usual service are not available. 


Moving Forward

The AMA appreciates CMS’s genuine desire to reduce documentation burdens on physicians to allow them to focus on patients over paperwork. We applaud the effort to reduce administrative burdens as it promises to improve both patient and physician experiences with care.  The AMA has heard concerns from some specialty societies regarding the payment policy changes. We have been in touch with CMS and the agency has indicated its willingness to work with the physician community on possible modifications to the proposal.  The AMA is focused on offering constructive recommendations that advance the twin goals of reducing administrative burdens and payment policies that enable physicians to deliver high quality care for seniors. As part of our regular course of business, the AMA will convene discussions with CMS, state and national specialty societies to develop our comments on the E & M coding and other issues in the +1500 pages of the proposed rule (Sept. 10 deadline for comments).

The Florida Medical Association is also weighing in on the proposed rule and calling for physicians to respond. Please click here to read a letter from Florida Medical Association President Dr. Corey Howard.