by Marilyn Rissmiller, CMS Senior Director of Health Care Financing

In late July the Centers for Medicare and Medicaid Services (federal CMS) released the proposed fee schedule rule for 2020. In short, the good news is that the federal CMS accepted the recommendations from the American Medical Association (AMA) and RVS Update Committee (RUC) and will not collapse the evaluation and management (E/M) levels with a blended payment rate as previously proposed.

The AMA and federal CMS worked together to modify the office visit policy while retaining the modifications that reduce the documentation burden. The CPT Editorial Panel and the RUC proposed revisions to simplify the guidelines and code descriptions and increase their value. The CPT coding changes will retain five levels of coding for established patients and reduce the number of levels for new patients to four. (CPT code 99201 will be deleted.) The proposed changes to the E/M coding and payment will go into effect in 2021.

Under the new documentation guidelines, history and examination alone will no longer select the level of the E/M code. Rather the code selection can either be based on the medical decision-making or the time spent on the date of the encounter. Under the new guidelines the outdated system of counting the number of body systems/areas reviewed and examined will no longer apply, and these components will only need to be performed (and documented) when and to the extent medically necessary and clinically appropriate for the patient.

The effective date of these changes was extended until 2021 in recognition of the time needed for physicians to become familiar with the new documentation requirements. The AMA has established a website dedicated to providing physicians with resources and training tools to help. That website is

In the meantime, the documentation requirements that were put in place for 2019 will remain in effect; that is the elimination of the requirement to document medical necessity of furnishing visits in the home rather than in the office; and elimination of requirements for the physician to re-record elements of the history and physical exam when there is evidence that the information has been reviewed and updated.

The proposed rule also included changes for 2020 to the Merit-based Incentive Payment System (MIPS) and expanded access to treatment for opioid use disorder. More information on the proposed fee schedule rule can be found on the federal CMS website at

Categories: Communications, Colorado Medicine