CMS Delays Simplified E/M Payment Structure in Final Rule on 2019 Fee Schedule

For 2019, the Centers for Medicare and Medicaid Services (CMS) has reduced administrative burdens on physicians associated with documentation and preserved separate payments for each of the existing levels of evaluation and management (E/M) services used to describe care for new and established patients in outpatient settings.

These provisions are part of the final rule on the 2019 Medicare Physician Fee Schedule, released by CMS in early November. In its original August proposal, CMS proposed a single “flat payment rate” for level 2 through level 5 E/M services provided in outpatient settings. This change would have resulted in physicians being paid a single rate for those services regardless of the complexity of the work a patient requires.

CMS is delaying the implementation of the proposed simplified payment structure until 2021 and has modified its original proposal. In 2021, CMS plans to collapse the payment for levels 2 through 4 for outpatient visits but will retain a separate payment amount for level 5 services.

In the meantime, CMS has adopted several of the documentation changes for which APA advocated in comments it submitted on the proposed rule. Beginning on January 1, 2019, CMS will no longer require physicians to document medical necessity for treating patients in their home rather than in the office; no longer require physicians to re-record elements of a patient’s history and exam when there is documentation that those items have been reviewed and updated; and will allow physicians to indicate that they have reviewed and verified information on the chief complaint and history that are already documented in the record by ancillary staff or the patient. These changes are expected to reduce administrative burden on physicians associated with documentation.

Physicians are to continue using either the 1995 or 1997 documentation guidelines for E/M code selection.

The fee schedule also includes important changes to requirements around electronic health records, the Merit-Based Incentive Payment System, and the use of quality measures.

Staff at APA are continuing to analyze the fee schedule. Members who have questions should contact the APA Practice Management Helpline at (800) 343-4671. Look for the December 21 issue of Psychiatric News for complete coverage of the fee schedule.

Detailed information on the fee schedule is posted at the CMS website.

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