The 2019 Medicare Physician Fee Schedule Rule, as proposed by the Centers for Medicare and Medicaid Services (CMS) in July 2018, garnered thousands of comments from the physician community. The overwhelming majority of these focused on the CMS proposal to blend the 5 levels of office visit codes into 2 level 1s, and then to combine levels 2 to 5. As I have anticipated, the proposal was not well-received. Couched in terms of reducing physician burden, it sounded good until one realized that most physicians would find their reimbursement drastically reduced. Rheumatologists were projected to be hit especially hard with a reduction in Medicare payments of 7% to 20%, depending upon the physician’s payer and service mix.
Here are the changes that will be effective January 1, 2019:
- Medicare will no longer require a physician or nonphysician practitioner to document the medical necessity of furnishing a home visit rather than having the patient seen in the office. Because of the slightly higher allowable for home visits over office visits, a requirement to document why the beneficiary could not have come into the office has been required
- When documenting office visits when relevant information is already contained in the medical record, practitioners may choose to focus their documentation on what has changed since the last visit, or on pertinent items that have not changed. There will no longer be a requirement for rerecording the defined list of required elements if there is evidence that the practitioner reviewed the previous information and updated it as needed
- For new and established patients for Evaluation & Management (E/M) office/outpatient visits, practitioners need not re-enter in the medical record information about the patient’s chief complaint and history that has already been entered by ancillary staff or the beneficiary. The practitioner may simply indicate in the medical record that he or she reviewed and verified this information
- Practitioners should still review previous data, update as necessary, and indicate in the medical record that they have done so.
Physicians and their staff should keep in mind that these changes are only for Medicare beneficiaries, and only when reporting E/M office visit codes. We should be on the lookout for further information and guidance on these changes from CMS and other payers.
Going forward, physicians must remain vigilant as CMS does intend to implement significant reductions in the current payment variation in E/M office/outpatient visit levels by paying a single blended rate for E/M office/outpatient visit levels 2, 3, and 4 (one for established and another for new patient visits) beginning in 2021. This will result in 3 levels of service, rather than the current 5, and will, of course, result in payment reductions.