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AMA and Medical Groups Respond to the CMS Proposed E/M Changes

Source: Emily Hill, PA, AAPM Coding Consultant

As noted in a previous e-news article, CMS proposed extensive changes to documentation and payment for new and established office visit Evaluation and Management (E/M) services in the July 27, 2018 Federal Register. CMS proposed a new, single blended payment rates for new and established patients for office/outpatient E/M level 2 through 5 visits. In conjunction with that, documentation requirements would be significantly reduced as part of its "Patients Over Paperwork" Initiative.

While the AMA and many specialty societies appreciate and welcome the proposed documentation changes, there is significant concern over the proposal to collapse eight E/M payments into two. In addition to the potential unintended consequences that would result from implementation, including limiting access to care for the sickest of patients, there are numerous unanswered questions. The AMA and approximately 150 medical associations, including AAPM, sent a letter to CMS outlining their concerns. The letter further indicated support for the creation of an E/M Workgroup to develop a new E/M coding structure and consider relativity issues for these office visit services.

To that end, the Chairs of the CPT Editorial Panel and the AMA/Specialty Society RVS Update Committee (RUC) created an E/M Workgroup with physicians and other health professionals with expertise in defining and valuing codes, and who also use the office visit codes to describe and bill for services provided to Medicare patients. The charge to this workgroup is to analyze the E/M coding and payment issues to arrive at concrete solutions that can be provided to CMS in time for implementation in the 2020 Medicare Physician Fee Schedule.

The Workgroup is reaching out to a wide group of stakeholders for input and assistance in reaching this goal. A series of surveys and conference calls are being conducted to solicit feedback from specialty societies and healthcare professional organizations. Members and staff from AAPM's Coding and Reimbursement Committee are monitoring the calls and activities of the Workgroup.

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