BREAKING NEWS: CMS Proposes to Change E&M Coding

by  Nicole Olsen, QCC
Aug 15th, 2018

On July 16th 2018, anyone subscribed to the CMS Quality Payment Program received an e-mail containing a letter to doctors from Seem Verma, Administrator of the Centers for Medicare and Medicaid Services (CMS). There are some widespread changes proposed in this letter of which you need to be aware.

Where the big proposed change is coming, however, is in your Evaluation & Management or E&M Codes:
“We’ve proposed to move from a system with separate documentation requirements for each of the 4 levels that physicians use to a system with just one set of requirements, and one payment level each for new and established patients. Most specialties would see changes in their overall Medicare payments in the range of 1-2 percent up or down from this policy, but we believe that any small negative payment adjustments would be outweighed by the significant reduction in documentation burden.”

To be clear, this would mean removing the 5 levels of your 99201 – 99205 and 99211 – 99215, of which you can receive reimbursement at different rates depending on the level of your visit. This would replace those levels with a single visit with a single reimbursement rate. This will affect specialty providers the most, who typically bill at a higher level due to more complex office visits. Now a cardiologist seeing a patient with advanced cardiovascular disease would be reimbursed the same as a primary care physician treating someone with a cold.

The facts are, at this point we don’t have a lot of facts. We don’t know what the new single reimbursement rate would be, so quantifying that “1-2 percent” change in reimbursement is difficult to calculate. However, we will continue to watch for further developments on this issue and make sure you are informed. CMS has stated they welcome your thoughts and proposals on this topic, so if you have concerns, make sure to make your voices heard. Right now, this is a proposed change and nothing official has been done. Provider feedback will be critical in making sure this change benefits not only the patients, but the providers treating them as well.