CMS Proposed Revisions Under the PFS

Stethoscope and laptop

In an effort to increase the amount of time doctors spend with patients and reduce Medicare paperwork, the Centers for Medicare & Medicaid Services (CMS) has released its proposed documentation changes for 2019 in the Federal Register, along with its proposed rule to streamline the Evaluation and Management (E/M) payment under the Medicare Physician Fee Schedule (PFS). Some of the proposed changes to reduce administrative burdens are:

  • Allowing practitioners to choose to document E/M visits by medical decision making or time instead of applying the current 1995 or 1997 E/M documentation guidelines
  • Practitioners who choose to use time to document E/M visits will be required to document the medical necessity of the visit and show the total amount of face-to-face time spent with the patient

What prompted this change? Stakeholders have said the 1995 and 1997 documentation guidelines for E/M visits are clinically outdated—particularly history and exam—and may not reflect the most clinically meaningful or appropriate differences in patient complexity and care. Furthermore, the guidelines may not reflect changes in technology or, in particular, the way electronic medical records have changed documentation and the patient’s medical record.

Some of the proposed changes to modernize the Medicare PFS involve recognizing and paying separately for the following new add-on codes and implementing single blended payment rates for new and established patients for E/M level 2 through 5 visits. The new minimum documentation standard means practitioners would only need to document information needed to support a level 2 E/M visit for Medicare PFS payment purposes. The proposed add-on codes and payments are:

  • Brief Communication Technology-Based Service, e.g., Virtual Check-In (Healthcare Common Procedure Coding System (HCPCS) code GVCI1)
  • Remote Evaluation of Recorded Video and/or Images Submitted by Patient (HCPCS code GRAS1)
  • Chronic Care Remote Physiologic Monitoring (Current Procedural Terminology (CPT) codes 990X0, 990X1 and 994X9)
  • Internet Consultation (CPT codes 994X6, 994X0, 99446, 99447, 99448 and 99449)

CMS Proposed Revisions Under the PFS - Chart

CMS has published a fact sheet on the PFS proposals for 2019 and is soliciting public comment on the proposal. For more information on the proposed rule, visit the CMS website or submit a comment to the Federal Register by September 10, 2018.

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