AMA, Providers Applaud Proposed Changes to E/M Codes, Payment

August 07, 2019 - CMS is receiving praise from major industry stakeholders after proposing to retract a recent final rule that will collapse evaluation and management (E/M) codes and pay providers a blended rate for office visits starting in 2021.

As required by law, the CY 2020 Physician Fee Schedule (PFS) proposed rule released on July 29 included an update to the conversion factor for Medicare physician reimbursement ($36.09, a slight increase above the CY 2019 conversion rate of $36.04).

The proposed rule also contained several policies that aim to reduce administrative burden for providers and improve health outcomes, including allowing providers to review and verify notes for other members of a medical team, increasing payments for transitional care management and adding chronic care management codes, and establishing reimbursement for opioid use disorder treatment services.

But one proposal in particular is garnering industry praise. Major industry stakeholders, including the American Medical Association (AMA), are applauding CMS for proposing changes to E/M codes and payment.

In the proposed rule, CMS announces its intentions to pull back on establishing blended payment rates for established patient office visits coded as E/M levels 2 through 4. Instead, the rule would revert to separate codes and payment rates for the five E/M levels.

Although, the rule would reduce the number of levels to four for office/outpatient E/M visits for new patients and revise certain code definitions, CMS pointed out in the proposed rule.

“The proposed changes to documenting and coding for office visits will streamline reporting requirements, reduce note bloat, improve workflow, and contribute to a better environment for health care professionals and their Medicare patients,” Patrice A. Harris, MD, MA, president of AMA, said in a recent statement.

The American College of Physicians (ACP), American College of Rheumatology (ACR), and Community Oncology Alliance agreed in respective statements.

ACP has been in staunch opposition to collapsing E/M codes into a single blended payment rate. The group argued in September 2018 that the changes to E/M codes and payments “do not appropriately recognize the value of cognitive care required to treat complex patients.”

Other major industry groups also decried the blended payment rate, including the American Hospital Association (AHA).

“By reducing payments for many providers, the proposal to collapse the payment rates for E/M visits devalues providers’ time, increasing the already heavy pressure they face to maximize the number of patients they see each day,” the hospital association wrote to CMS last year.

The AHA also pointed out that the policy could incentivize providers to see patients multiple times for the same issues or steer them to higher cost settings, such as emergency departments. CMS addressed these concerns in the new CY 2020 Physician Fee Schedule proposed rule.

CMS noted in the rule that the agency decided to reverse course after provides in outreach sessions expressed concerns that the blended payment rates would inappropriately incent multiple or shorter patient visits, which could result in providers treating less complex patients.

Industry groups like the Community Oncology Alliance commended CMS for heeding stakeholder advice.

“Regarding the Medicare Physician Fee Schedule (MPFS) proposal for calendar year 2020, it is clear that CMS has continued to listen to the feedback of community oncology and recognizes the complexity of cancer care. Instead of simply collapsing or reducing reimbursement for evaluation and management (E&M) services as proposed in past years, CMS has realized that the complexity of cancer care is valuable, as is the expertise and time of the community oncologists who treat patients with complex cancers,” said Ted Okon, executive director of the organization.

ACR added that the proposed changes would also support specialist reimbursement for high-quality care.

“Rheumatologists and other cognitive specialists should be adequately reimbursed for the time-intensive, high-value services they provide to Medicare beneficiaries,” stated Paula Marchetta, MD, MBA, the organization’s president. “The proposed changes would more closely align reimbursement for E/M services with the time and expertise they require, and will help ensure millions of Medicare beneficiaries continue to receive these vital healthcare services.”

CMS plans to publish the proposed rule on August 14. Stakeholders can comment on the proposed changes until September 27, 2019.