170 medical groups submit unified comments on federal CMS payment rule
by Staff report
Featured in the September/October 2018 Colorado Medicine.
The American Medical Association, Colorado Medical Society and 168 other medical groups sent a letter to Seema Verma, administrator of the Centers for Medicare and Medicaid Services, regarding the administration’s proposals included in the 2019 Medicare physician payment rule. In an effort to reduce documentation, the Centers for Medicare and Medicaid Services proposed collapsing payment rates for eight office visit services for new and established patients down to two each.
While the organizations strongly support reducing administrative burdens on physicians so they can devote more time to patient care, they oppose the proposed collapse of payment rates as “it could hurt physicians and other health care professionals in specialties that treat the sickest patients, as well as those who provide comprehensive primary care, ultimately jeopardizing patients’ access to care,” the letter states.
In an effort to help the federal CMS work through the nuances of appropriate coding, payment and documentation requirements for different levels of evaluation and management (E&M) services, the AMA rapidly convened a workgroup on Current Procedural Terminology (CPT) and Relative Value Scale Update Committee (RUC) on E&M comprising physicians and other health professionals with deep expertise in defining and valuing codes, who also use the office visit codes to describe and bill for services provided to Medicare patients. Through an aggressive meeting schedule, the workgroup plans to develop a CPT proposal by early November. The CPT editorial panel would then vote on the recommendations in February 2019 and the RUC would develop revaluations by May, in time for implementation in the 2020 Medicare Physician Fee Schedule.
Regarding reducing administrative burden, the organizations urge immediate adoption of three documentation policy changes included in the proposed rule.
- Changing the required documentation of the patient’s history to focus only on the interval history since the previous visit;
- Eliminating the requirement for physicians to re-document information that has already been documented in the patient’s record by practice staff or by the patient; and
- Removing the need to justify providing a home visit instead of an office visit.
“We encourage the administration to adopt in the final rule the documentation changes outlined above. These changes reflect significant progress in your Patients Over Paperwork Initiative. Such policy modifications will significantly reduce the documentation burden so health care professionals can spend more time with patients. We also urge the administration to set aside its office visit and multiple service proposals, fully embrace the assistance of the workgroup and work together with the medical community on a mutually agreeable policy that will achieve our shared goal of simplifying E&M documentation burdens while mitigating any unintended consequences.”