The Chicago-based American Medical Association and some 150 medical groups have sent a letter to Centers for Medicare and Medicaid Services (CMS) Administrator Seema Verma showing support for the federal agency’s recent proposals around Evaluation and Management (E&M) coding reform.
Earlier this summer, CMS proposed changes that the agency said will “fundamentally improve the nation’s healthcare system and help restore the doctor-patient relationship by empowering clinicians to use their electronic health records (EHRs) to document clinically meaningful information.”
As part of the July announcement, officials from CMS and the Office of the National Coordinator for Health Information Technology (ONC) said they have heard from stakeholders that CMS’ extensive documentation requirements for E&M codes have resulted in unintended consequences.
To meet these documentation requirements, providers have to create medical records that are a collection of predefined templates and boilerplate text for billing purposes, in many cases reflecting very little about the patients’ actual medical care or story, according to federal officials.
As such, new provisions in the proposed CY 2019 Physician Fee Scheduleؙ from CMS would help to “free” EHRs, officials said. And if the proposals were to get finalized, clinicians would save an estimated 51 hours per year if 40 percent of their patients are in Medicare, CMS predicted.
Now, plenty of physician groups are showing strong support for the proposals. They wrote in the letter, dated Aug. 27, “The proposals included in the 2019 Medicare physician payment rule demonstrate that you listened to our members’ concerns about the significant administrative burdens due to the documentation requirements associated with E&M services. We are grateful for your efforts to simplify these requirements and reduce their associated red tape.”
They continued, “Excessive E/M documentation requirements do not just take time away from patient care; they also make it more difficult to locate medical information in patients’ records that is necessary to provide high quality care. Physicians and other healthcare professionals are extremely frustrated by ‘note bloat,’ with pages and pages of redundant information that makes it difficult to quickly find important information about the patient’s present illness or most recent test results.”
The groups added that many of the documentation policy changes included in the proposed rule “would go a long way toward alleviating this problem and the undersigned organizations urge immediate adoption.” These changes include:
- Changing the required documentation of the patient’s history to focus only on the interval history since the previous visit;
- Eliminating the requirement for physicians to re-document information that has already been documented in the patient’s record by practice staff or by the patient; and
- Removing the need to justify providing a home visit instead of an office visit.
The physician groups who signed the letter did write that they do oppose CMS’ proposal to collapse payment rates for eight office visit services for new and established patients down to two each, as they believe that there are a number of unanswered questions and potential unintended consequences that would result from the coding policies in the proposed rule.
They wrote, “We oppose the implementation of this proposal because it could hurt physicians and other healthcare professionals in specialties that treat the sickest patients, as well as those who provide comprehensive primary care, ultimately jeopardizing patients’ access to care. We also urge that the new multiple service payment reduction policy in the proposed rule not be adopted as the issue of multiple services on the same day of service was factored into prior valuations of the affected codes. The proposal also has significant impact on certain services, such as chemotherapy administration, that may be an unintended consequence of altering the current practice expense methodology to accommodate the proposal.”
It should be noted than array of other groups, largely specialty associations and alliances, also wrote a letter to CMS on these proposals, specifically opposing this change. Similar to the above-mentioned medical groups, they noted that the proposals to consolidate the billing codes for physician evaluation and management so as to pay the same amount for office visits regardless of the complexity of the patient “would cut payments for visits that are currently reimbursed at higher levels than simple or routine office visits, penalizing doctors who treat sicker patients or patients with multiple conditions.”
The medical group organizations also said they support the American Medical Association’s creation of a workgroup of physicians and other health professionals with deep 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 in order to arrive at concrete solutions that can be provided to CMS in time for implementation in the 2020 Medicare Physician Fee Schedule, they wrote.
