CMS has once again issued significant proposed changes to the Medicare Physician Fee Schedule (MPFS) for 2019 affecting Evaluation and Management (E/M) services. The changes are similar to the 2018 proposed changes which included removal of the history and exam documentation requirements and revision of the guidelines to base all code selections on medical decision making (MDM) and time. CMS also proposes to allow practitioners to simply review and verify what has changed since the last visit rather than re-entering it. CMS believes MDM and time are more significant factors in determining the level of service and aim to reduce the documentation burden on providers, while also improving payment accuracy for E/M visits.
CMS is seeking comments regarding these changes, the implementation timeframe of their proposals, and also how documentation guidelines for MDM might be changed in future years. The deadline to provide formal comments is September 10, 2018.
The proposed rule is scheduled to be published on 7/27/18 and can be viewed at: https://www.federalregister.gov/documents/2018/07/27/2018-14985/medicare-program-revisions-to-payment-policies-under-the-physician-fee-schedule-and-other-revisions