Approximately 170 groups provide comment to CMS on proposed E/M changes

September 10, 2018

The American Medical Association and about 170 medical groups recently sent a letter to CMS administrator Seema Verma commenting on proposed E/M policy changes in the 2019 Medicare Physician Fee Schedule (MPFS) proposed rule.

According to the letter, the groups agree the following MPFS proposals would eliminate redundant E/M reporting requirements and reduce provider burden:

  • Eliminating the need for physicians to re-document information that is already documented in to the patient’s medical record
  • Removing the requirement to justify providing a home visit rather than an office visit
  • Revising documentation requirements for patient history to focus on interval history since the patient’s previous visit

In contrast, the organizations urged CMS to rethink its proposal to collapse payment rates for eight office visit services for new and established patients.

In the letter, the organizations explain that there are too many unanswered questions and potential unintended consequences that would result from the implementation of this new payment structure. Specifically, the organizations oppose the implementation of this proposal because they believe it could negatively impact physicians in specialties that treat the sickest patients and jeopardize patient access to care.

A fact sheet on proposed payment provisions for calendar year 2019 can be found here. The deadline to submit comments to CMS on the proposed rule ended today.