The revisions will become effective Jan. 1, 2021, and the content will not be included in the 2020 CPT code set release.
The AMA is encouraging physician practices to start planning for the operational, infrastructural and administrative workflow adjustments that will result from this overhaul—some of those changes will involve information systems. It offers the following checklist as a way to prepare for the changes.
Identify a project lead
The transition to the revised E/M office visit coding guidelines will require staff education, review of internal policies and procedures, and financial tracking. Practices should name a project lead who is charged with leading the transition. This project lead should study the AMA’s information on organizational leadership and change management for leading change with the practice.
Schedule team preparation time
The best way to educate those within a practice about upcoming changes will be to walk through them with the practice’s physicians, other clinical staff and administrative personnel. Practices should schedule time for in-person gatherings to review the changes and to surface and address questions. The AMA provides guidance for how to run an efficient and productive team meeting.
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Update practice protocols
A practice must update its procedures and protocols to be consistent with the new guidelines. AMA recommends leveraging a practice’s established coding resources and expertise early in the update process.
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Consider coding support
There are significant changes to the codes and documentation for office visits. The AMA offers resources on ancillary staff E/M documentation and a module on team documentation. Use all appropriate coding resources to properly prepare for these revisions—the AMA offers an educational website to learn more about the changes and take the module to see how the revisions will help reduce administrative burden.
Be aware of medical malpractice liability
Although the requirements around E/M documentation may have lessened or become more flexible, physicians should still carefully document the work that is being done and know how to protect themselves from medical malpractice suits.
Guard against fraud and abuse law infractions
The False Claims Act, and other federal and state fraud and abuse laws remain in effect. Although the new E/M office visit coding guidelines allow greater flexibility, practices should continue to document appropriately and guard against inadvertent overbilling. If a practice does bill appropriately under the new E/M documentation guidelines but still receives an overpayment demand, the AMA offers resources to help it navigate the audit and appeal process.
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Update the practice’s compliance plan
Many practices have a compliance plan to help avoid ethical and legal mistakes. The Department of Health and Human Services has a roadmap to help physician practices develop and implement a compliance plan. As your practice undergoes the transition to the new E/M guidance, ensure that your updated protocols and procedures remain consistent with your current compliance plan.
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Check with the practice’s electronic health record vendor
Practices should communicate with their EHR vendors to confirm their schedule for implementing changes in E/M office visit codes. Efforts are underway to ensure that EHR vendors’ changes enable practices to make easy-to-implement changes in their systems.
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Assess the financial impact
Practices should guard against an unanticipated financial impact by understanding the rules in advance and performing a prospective financial analysis. This may help practices anticipate a dip or increase in revenue and aid in other practice business decisions.
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Understand additional employer or payer medical liability coverage requirements
Employers or payers may still require documentation of additional information above and beyond the new E/M office visit coding guidelines. Physicians should carefully evaluate the flexibilities allowed under the new guidelines and ensure that their documentation will satisfy any other obligations and requirements that they may be expected to fulfill.