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Patient, Provider Groups Tell CMS Proposed E/M Service Cuts Will Hurt Sickest Patients

Jaime Rosenberg
Over 200 patient and provider groups have written to CMS, saying that proposed consolidation of evaluation and management billing codes will adversely affect the sickest Medicare patients and the physicians that treat them.
Among the myriad of proposals included in CMS’ 2019 Medicare physician payment rule are proposed changes to evaluation and management (E/M) documentation and billing. While some proposed changes have brought nods of approval, others have brought warnings.

In a letter from the American Medical Association (AMA) and 150 other medical groups, the organizations applauded CMS’ proposals that would alleviate administrative burdens of documentation requirements, which often take time away from the patient and make it hard to locate the appropriate medical information in a patient’s record.

Proposals highlighted in the letter that would help alleviate some of the burden include changing the required documentation of the patient’s history to focus only on the interval history since the previous visit, eliminating the requirement for physicians to redocument information that has already been documented in the patient’s record by practice staff or the patient, and removing the need to justify providing a home visit rather than an office visit.
“Implementation of these policies will streamline documentation requirements, reduce note bloat, improve workflow, and contribute to a better environment for healthcare professional and their Medicare patients,” states the letter.

However, another proposed change—consolidating E/M billing codes—have provider groups concerned that the sickest Medicare patients and the providers who care for them will suffer. Currently, E/M billing codes are based on a patient’s complexity. Under the proposed rule, providers would be reimbursed the same amount regardless of the complexity of the patient.

Whether a patient comes in for a complex issue or for the sniffles, the billing would be the same, explained Angus Worthing, MD, FACP, FACR, chair of the American College of Rheumatology (ACR) Government Affairs Committee, in an interview with The American Journal of Managed Care®. According to Worthing, the proposed rule would have several consequences, such as penalizing doctors for taking care of complex patients, leading them to address one problem at a time, rather than all of them.

The letter from AMA and the 150 other medical groups also cited concerns with the proposed change, stating that there are a number of unanswered questions and potential unintended consequences that would affect physicians and other healthcare professionals that treat the sickest patients and would ultimately impact patient access to care.

A separate letter from 126 patients and provider groups, including ACR, applauded CMS for recognizing the problems with the current E/M documentation guidelines but urged to not move forward with the proposal because of concerns with the billing consolidation.

The letter notes that these time-intensive services—which include examinations, disease diagnosis and risk assessments, and care coordination—are already under-compensated and that additional payment cuts would worsen workplace shortages in already strained specialties like rheumatology.

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