Episode 1: Evaluation and Management Coding
An overview of recent changes to Evaluation and Management Coding as finalized in the 2019 Physician Fee Schedule.
>> Bill Polglase: Welcome to the CMS Beyond the Policy podcast. Today's edition of CMS Beyond the Policy podcast will focus on the 2019 physician fee schedule final rule. This is just one effort among many that the agency is taking to reduce burden, so that clinicians can focus more on their patients, rather than dealing with cumbersome paperwork.
Today I'm meeting with Dr. Kate Goodrich, the Chief Medical Officer at the Centers for Medicare and Medicaid Services, and a clinical professor of medicine at George Washington Hospital Center, along with Dr. Anand Shah, Chief Medical Officer of the CMS Innovation Center, and a radiation oncologist at the FDA and NIH. Each year at CMS, we issue a final rule to update payments and policies in the upcoming calendar year for doctors and other clinicians participating in Medicare. One of our most recent published final rules is the physician fee schedule for 2019. This is a complicated topic for sure, so we wanted to focus our first-ever CMS podcast on discussing what's in the PFS final rule. I'm pleased to be here with Dr. Kate Goodrich, CMS Chief Medical Officer.
Dr. Goodrich, what is CMS trying to address with these policies?
>> Kate Goodrich: Thanks, Bill. We're trying to address a number of things, but in particular we're really focusing on reducing regulatory burdens on clinicians. CMS has heard from physicians and other clinicians for some time now that excessive paperwork and unnecessary regulations, including coding requirements for evaluation and management -- or E&M as we call it -- are detracting from patient care. The current 1995 and 1997 E&M framework was built on a model of clinical care involving complaint or symptom-based face-to-face encounters between a patient and a clinician. But, since the 1990s, the nature of clinical care has really changed. There's a much greater emphasis on patient-centered collaborative models of care with clinical teams that work together to manage chronic conditions.
The current way that clinicians work -- which often requires complex medical decision-making and care coordination. For example, a primary care doctor who's caring for a Medicare patient with multiple chronic conditions and is coordinating that care between the patient and the multiple specialists helping to care for that patient. That framework just isn't well-represented in the current E&M codes. As a result, clinicians find themselves having to perform and document clinical activity that may be of only marginal relevance to the visit but is required in order to receive the level of payment that their effort deserves.
The current system includes five levels for E&M for office visits. Level one is used primarily by non-physician practitioners, whereas physicians and other clinicians, such as nurse practitioners or physicians' assistants, typically use codes for levels two through five. There are different documentation requirements for each level. That's a lot to remember. Since the significant majority of visits are reported at levels three and four, most visits require documentation of complexity well beyond the minimum. The policies in this final rule will help to reduce administrative burden by simplifying documentation requirements, and they will improve interoperability so that Medicare providers can operate with greater flexibility and coordination with other providers in order to allow them to keep their focus where it should be, on the patient.
In addition, we are taking new approaches to enhancing the ability of Medicare patients to make use of telecommunications technology for other types of services.
>> Bill Polglase: Dr. Shah, how do you think these changes will impact your relationships with the patients you see?
>> Anand Shah: Bill, these final rules restore the vital patient-doctor relationship like giving clinicians and their staff flexibility in documentation for billing purposes and freeing up more time for them to see and care for their patients. We integrated the extensive input we received from the medical community and other stakeholders, and we look forward to the improvements these phased-in changes will bring in terms of allowing clinicians to spend more time with their patients and enhance the care they provide.
>> Bill Polglase: Dr. Goodrich, can you give us some specifics that will matter to clinicians?
>> Kate Goodrich: Absolutely. First, it's important to note that one of the things that we really tried hard to do in this effort is to listen. We listened both to practicing clinicians; we also listened to the organizations that represented them. And while they recognize and appreciate our burden-reduction efforts, they did urge us to take more time before implementing significant payment changes. They also identified several concerns about various aspects of our proposals.
So, we listened to all of these concerns, and we finalized policies that will be implemented over several years. Starting in January of 2019, we will be reducing burden to provide some immediate relief for doctors and other clinicians. These include removing redundancy in the E&M documentation. So, for example, we'll no longer require clinicians to re-enter certain information into the medical record that was already entered by support staff, or even by Medicare patients themselves. CMS also will reduce unnecessary physician supervision of radiologist assistants for diagnostic tests. And we are removing burdensome and overly-complex functional status reporting requirements for outpatient therapy.
We're also finalizing other documentation, coding, and payment policies for 2021 instead of 2019 in order to give stakeholders more time to prepare. And we're also making important changes to the proposed policies based upon the comments we received.
>> Bill Polglase: I know some of the evaluation and management documentation guidelines have been in place since 1995, and updated guidelines issued in 1997. Dr. Shah, are they being updated now?
>> Anand Shah: Bill, we're actually giving physicians a choice in how to document E&M office visits as we proposed. Physicians will be able to use medical decision-making or time instead of applying the current 1995 or 1997 E&M documentation guidelines, or, alternatively, they could continue using the current framework. I should also add that we're simplifying payments by establishing a single payment rate for E&M levels two through four office visits with one rate for new patients and another rate for established patients. Related to this, we're requiring that physicians will only need to meet documentation requirements associated with level two visits when performing these office visits, except when time defines a service. Clinicians can document additional information in the chart for clinical and other purposes. Again, most of the hundreds of millions of Medicare visits are billed at levels three and four. So, this will result in a significant burden reduction for the majority of visits.
>> Bill Polglase: And I know that based on comments received, we are keeping payments for level five E&M office visits separate in order to better account for the care and needs of particularly complex patients. Dr. Goodrich, can you talk a little bit more about this?
>> Kate Goodrich: Yes, I'd be happy to. We are finalizing additional adjustments that account for extended visits, as well as for the complexities of primary care and specialty care that is non-procedure based. In fact, in response to comments, we broadened the definition of the non-procedural specialty care. And we designed these add-on payments so that for most clinicians, additional documentation will not be necessary in order to report the codes. That's something many commenters raised concerns about, and we are committed to making that work.
After considering concerns raised by commenters in response to the proposed rule, we are not finalizing other aspects of our proposal such as reduced payment when E&M office visits are furnished on the same day as procedures or separate podiatry E&M visit codes. We'll also continue to work with the clinician community to make sure that we get it right. We want clinicians to be fairly compensated for taking care of Medicare patients, and in particularly the most complex patients.
>> Anand Shah: And I would also like to note that in addition to reducing burden, this final rule makes a real effort at improving access to care. We're modernizing the Medicare benefit to improve access to care with coverage for new tele-health benefits and, also, new options for virtual. It's not easy for people to get to their healthcare provider, whether they live in urban or rural communities. This is a way to get more accessible care and will create more opportunities for patients to connect with providers by leveraging the latest advances in technology.
>> Bill Polglase: How do you think this will impact how you, as physicians, deliver care?
>> Kate Goodrich: So, when I take care of Medicare patients, I'll be separately paid for interactions to assess whether or not a face-to-face visit is needed. So, if I do a brief phone call or a Skype call, or I review a picture that a patient texts me, I can submit a claim for that. Same goes for consultations with other professionals and remote physiologic monitoring that are currently bundled together.
>> Anand Shah: I should add we're also continuing to expand the list of services that clinicians can provide through tele-health, including prolonged preventive services that account for additional time when services like the welcome to Medicare preventive visit or the annual wellness visit are furnished.
>> Bill Polglase: Very interesting and impactful stuff. Dr. Goodrich and Dr. Shah, thanks for making the time to speak with me about these important policy changes, and thanks to you in our audience for listening. For the CMS Beyond the Policy podcast, I'm Bill Polglase.
You can subscribe to this podcast through iTunes or whatever podcast service you use. We'll be back soon with another edition of CMS Beyond the Policy. This podcast is brought to you by the U.S. Department of Health and Human Services.
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