CMS delays changes for evaluation and management codes until 2021
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Responding to opposition from the physician community, CMS has agreed to delay Medicare coding changes for evaluation and management services until 2021. If implemented by CMS for next year, as planned, an AMA analysis indicated that nephrologists could have seen a 13% drop in revenue.
The coding changes were part of a proposed rule released by CMS in July for the Medicare Physician Fee Schedule (PFS), which updates regulations and payments each year for physician services. In the PFS, the agency proposed to consolidate codes for outpatient new visits (CPT codes 99201 to 99205) and follow-up visits (99211 to 99215) and collapse payments from five levels for each set of codes down to two levels.
“On the surface, this proposal has some merit,” wrote nephrologist Jeffrey Giullian, MD, MBA, FASN, in a commentary for Healio/Nephrology in October. “By streamlining documentation requirements, removing antiquated 1995 and 1997 guidelines, and reducing redundancy in physician notes, the CMS goal is to improve the clarity of medical records which would only require pertinent facts, findings and observations.”
However, the proposed changes would likely “increase burden in the short run, reduce reimbursement for nephrologists, shift revenue to certain stakeholders and decrease physician ability to spend quality time with complex patients. In short order, this new fee structure will reduce nephrologists’ ability to run an efficient outpatient clinic,” wrote Giullian.
In a Sept. 10 letter to CMS Administrator Seema Verma, the Patient-Centered Evaluation and Management Services Coalition, made up of a number of medical societies, expressed concern about consolidating the visit codes, saying while it “appreciates the intent behind CMS’s proposals to reduce visit codes ... we are concerned about the payment proposals and strongly urge CMS to withdraw all of its payment proposals and work closely with the coalition and other stakeholders to consider whether there are alternatives that will improve upon the current structure.” The coalition asked the agency to wait at least 1 year to finalize any payment proposals to allow viewpoints from the coalition and other stakeholders “to create a coding structure that better meets the agency’s goals of improving patient care and reducing burden but without the undesirable consequences” of the proposed rule. The 13-page letter was signed by 41 organizations, including the American Society of Nephrology, the Renal Physicians Association and the American Society of Pediatric Nephrology.
CMS said in a letter to physicians that it received more than 15,000 responses to the PFS proposed rule.
Other measures that were part of the final rule that will help reduce documentation burden, CMS said, included no longer requiring physician to redocument information already provided by the patient or staff, and to only require documentation of the patient’s history since the last visit. – by Mark E. Neumann
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