On November 1, 2018, the Centers for Medicare & Medicaid Services (CMS) issued a final rule
updating payment policies and rates for physicians paid in 2019 under the Medicare Physician Fee Schedule (MPFS). This final rule contains some positive changes in the documentation requirements for visits billed as evaluation and management (E/M) services.
Specifically, CMS has:
- Changed the required documentation of the patient’s history to focus only on the interval history since the previous visit.
- Eliminated the requirement for the physician to re-document information that has already been documented in the patient’s record by practice staff or by the patient.
- Removed the need to justify providing a home visit instead of an office visit.
- Declined to move forward on the proposal to reduce payment for office visits when performed on the same day as another service.
AANEM is grateful that CMS listened to our comments
regarding the complete overhaul of the reimbursement structure for E/M codes that would have resulted in significant cuts to reimbursement to all physicians who treat medically complex patients. The E/M coding and payment structure will remain unchanged in 2019 and 2020. This 2-year window for implementation of the restructuring of the E/M codes will give the AANEM time to work with the CPT/RUC Workgroup tasked with renovating the coding for E/M office/outpatient services as well as CMS to make recommendations on this complicated topic.
AANEM staff is in the process of further analyzing this rule which includes updates to payment policies, payment rates, and the Quality Payment Program (QPP). Further information will be available in future AANEM publications and on AANEM’s website
. If you have any questions or concerns, please contact AANEM’s Policy department