Proposed Major Changes to E/M Services

CMS has proposed major changes to physician evaluation and management (E/M) services in the 2018 Medicare Proposed Physician Fee Schedule.  In their comments CMS indicated that the current history and exam documentation requirements may present an unnecessary burden to providers and the guidelines are potentially outdated.  They also noted that in light of electronic health record (EHR) technology, there is an increased potential of up-coding.

CMS is proposing to undertake a multi-year project to revise and update the guidelines in an effort to reduce provider burden and improve meaningful medical record documentation.

CMS is specifically seeking comments on the removal of the documentation requirements for history and physical exam for all E/M services indicating they believe medical-decision-making and time are the more significant factors in determining visit levels.

The deadline to provide formal comments is September 11, 2017.

The Proposed Rule is available at

We recommend providers review the Proposal but continue to focus their efforts on appropriate documentation and coding for E/M services.

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