Stakeholders urge CMS to eliminate inconsistencies in E/M reporting

CMS held a listening session on March 21 to gather input from stakeholders on potential updates to the E/M documentation guidelines. The current guidelines are considered outdated in light of medical advances and the advent of the electronic health record (EHR).

In the 2018 Medicare Physician Fee Schedule (MPFS) proposed rule, CMS sought comment on potential revisions to the guidelines from professionals who perform and bill E/M services, which were updated over 20 years ago, to better align E/M reporting with current medical practice.

Commenters expressed varying opinions, summarized in the 2018 MPFS final rule, and suggested that CMS provide additional avenues for collaboration prior to implementing any changes. The listening session served as a follow-up to the final rulemaking, released in November 2017, and is part of an ongoing effort to seek input from stakeholders on these topics.

During the 1.5-hour-long session administered by Marge Watchorn, deputy director with the division of practitioner services at CMS, attendees suggested that the following revisions be made to the E/M guidelines:

• Ensure payer consistency. Attendees noted that Medicare Administrative Contractors (MAC) have unique requirements for reporting the same codes. They urged CMS to work with regional payers to increase consistency in reporting and ensure that MACs are adhering to similar requirements.
• Place more emphasis on medical decision-making. CMS inquired about how much of a role of the current required components (history, physical exam, medical decision-making) play in supporting E/M visit levels for payment. Several attendees requested that the agency elevate the importance of medical decision-making in defining the severity of a patient encounter.
• Recognize team-based care. Commenters requested that the guidelines be revised to better reflect team-based care. According to attendees, the current rules are confusing because they do not clearly specify who can enter what information into the EHR.
• Reduce the number of E/M levels. Listeners commented that the E/M documentation requirements are repetitive, especially in the family and social history categories. They suggested that CMS reduce the number of E/M levels from 5 to 3 or 4, focusing less on patient history and more on medical decision making.

Suggestions made during this session will be considered for inclusion in the 2019 MPFS proposed rule, scheduled for release in early July.

An audio recording and written transcription of the call can be found here.