CMS discusses potential E/M updates at 2018 CPT Symposium

A CMS representative solicited input from audience members on potential revisions to E/M documentation guidelines at the AMA’s 2018 CPT Symposium in Chicago this week, continuing the agency’s outreach on E/M reform that began with this year’s Medicare Physician Fee Schedule (MPFS) proposed rule.

During a presentation Thursday, Marge Watchorn, deputy director of CMS’ Division of Practitioner Services, solicited input from the audience on how to reconfigure E/M documentation guidelines.

“With providers using the relatively old, and conflicting, 1995 or 1997 E/M guidelines, which were written well before the advent of EHRs, the agency is finally looking for methods to update and potentially unite its guidance,” said Shannon McCall, RHIA, CCS, CCS-P, CPC, CPC-I, CEMC, CRC, CCDS, director of HIM and coding for HCPro, an H3.Group division of Simplify Compliance LLC, in Middleton, Massachusetts, who attended the symposium.

Audience suggestions included:

• Adding criteria for counting chronic diseases, which could aid in risk adjustment
• Determining overall risk as part of prescription drug management (e.g., what can be counted if prescriptions are continued for ongoing medical problems versus new medications for new problems)
• Making a clear delineation between an expanded problem focused and detailed exam, as that may vary by Medicare Administrative Contractor
• Making the medical decision making component more prominent in determining E/M levels
• Outlining standards for copy and paste in EHR (e.g., bringing forward old information for the history section of the documentation) 

“It was a pleasant surprise to see CMS actively engaged in examining this outdated and very subjective area of CPT coding,” said McCall. “Hopefully, this will be just the beginning toward possible new E/M codes and guidelines that can be easily and clearly assigned. And they can also more accurately reimburses providers for the care provided, which will be a winning combination.”

The 2018 MPFS final rule provides additional stakeholder comments on E/M documentation guidelines, offered during comment solicitation for the proposed rule, and states that CMS will consider public feedback in future rulemaking.