E/M Coding Changes Delayed Until 2021

November 2018 ~

In the recently published final version of the 2019 Physician Fee Schedule (PFS) and Quality Payment Program (QPP), CMS modifies and delays certain proposed changes to evaluation and management (E/M) codes.

In the final rule, the agency both revised and delayed the proposal to collapse E/M service levels 2 to 5 into a single visit code with a single payment. Instead, effective 2021, CMS will pay a single rate for E/M visit levels 2 through 4 while maintaining the payment rate for level 5 for more complex patients to “better account for the care and needs of complex patients.”

To account for the additional resources needed for E/M visits levels 2 through 4, the agency will also offer a new “extended visit” add-on code in 2021. The federal agency will also offer add-on codes for primary care visits and visits for particular types of non-procedural specialized medical care.

The final 2019 PFS rule also paired E/M payment changes with documentation requirement updates. The rule will reduce E/M documentation requirements for all visit levels starting in CY 2019. Documentation changes in the final rule include:

• Elimination of the requirement to document medical necessity of a home visit in lieu of an office visit
• Providers can choose to choose their documentation on what has changed since the last visit or on pertinent items that have not changed for established patient visits when relevant information is already documented in the medical record
• Providers will not have to re-enter information on a patient’s chief complaint and history in the medical record that has already been recorded by an ancillary staff or the beneficiary
• Removal of potentially duplicative requirements for medical record notations that may have been previously included in the medical records by residents or other medical team members for E/M visits performed by teaching physicians

CMS Administrator, Seema Verma, stated in press release regarding the changes under final rule, “Today’s rule finalizes dramatic improvements for clinicians and patients and reflects extensive input from the medical community. Addressing clinician burnout is critical to keeping doctors in the workforce to meet the growing needs of America’s seniors. Today’s rule offers immediate relief from onerous requirements that contribute to burnout in the medical profession and detract from patient care.”

Source(s): RBMA; Health Leader’s Media; RevCycleIntelligence; MedPage Today;