In the 2019 Medicare Physician Fee Schedule proposed rule, the Centers for Medicare and Medicaid Services (CMS) included significant revisions to the way that evaluation and management (E/M) services would be reimbursed and documented.
The current E/M structure is outdated and does not reflect current care that is provided during office visits, particularly those provided by endocrinologists and other cognitive specialists.
According to CMS, the proposal is intended to reduce administrative burdens resulting from documentation requirements for complex services by only requiring physicians to document medical necessity and either the medical decision making, time, or existing documentation guidelines for a level 2 visit regardless of the level of service provided. CMS reforms to payment that are linked to this proposed documentation change. The agency is proposing to create a single payment rate for level 2 through 5 new and established patient office visits. To account the decreased reimbursement, the agency is proposing new add-on codes that can be billed for longer, more complex visits.
The Endocrine Society has advocated for revisions to the existing E/M code set for many years, including the revaluation and redefinition of these codes. The current E/M structure is outdated and does not reflect current care that is provided during office visits, particularly those provided by endocrinologists and other cognitive specialists. While we support revisions to the E/M codes, we believe that it must be done in a methodical, evidence-based manner to account for patient complexity, services rendered, and the impact that new technology may have on practice.
Because CMS’ approach reduces the reimbursement for the E/M codes that account for the most complex services, we are concerned that it will reduce access to care and exacerbate existing workforce shortages by forcing physicians to see additional patients to make up the difference in reimbursement. While CMS did propose new add on codes to address prolonged visits, we do not believe these codes will be used by a significant number of endocrinologists because of the time requirements. We also believe that the effort to consolidate level 2 through 5 E/M codes would penalize specialists, like endocrinologists, who treat more complex patients and require a higher degree of documentation regardless of Medicare’s requirements for billing.
While we support revisions to the E/M codes, we believe that it must be done in a methodical, evidence-based manner to account for patient complexity, services rendered, and the impact that new technology may have on practice.
In our comments on this proposal, we recommend that CMS delay the implementation of this proposal and use that time to model and consider other alternatives that recognize the complex cognitive work cognitive physicians provide and account for their expertise. While we support efforts to reduce administrative burdens and unnecessary paperwork, CMS should consider the level of documentation that is required for patients of greater complexity in terms of best practices. It is not our expectation that reducing documentation requirements for billing will actually reduce the level of documentation that is required for patients with complex or multiple diseases. We will continue to advocate for revisions to the existing E/M structure that account for the complex specialty care endocrinologists deliver to patients.
To see the full text of our comments to CMS on the proposed 2019 Medicare Physician Fee Schedule Rule, visit www.endocrine.org/advocacy/policy-communications. A summary of the proposed rule with Endocrine Society analysis can be seen at www.endocrine.org/advocacy/priorities-and-positions in the Additional Society Policy Documents section.
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