CMS proposed rule reduces Evaluation and Management coding burden
The Centers for Medicare and Medicaid Services on Thursday released a proposed rule for the Calendar Year 2019 Physician Fee Schedule designed to reduce overly burdensome regulations on providers in order to enable them to spend more time taking care of patients.
The initiative could greatly affect the time involved in using electronic health records and how clinicians interact with systems.
Part of the agency’s Patients Over Paperwork initiative, the CMS proposal is an attempt to “get government out of the way and providers taking care of their patients” by streamlining documentation requirements and modernizing Medicare payment policies, said Administrator Seema Verma during a conference call with members of the press.
In particular, CMS has set its sights on reducing the burden of Evaluation and Management (E&M) codes on physicians, who are required to document specific types of information in patients’ medical charts. E&M coding is the process by which physician-patient encounters are translated into five-digit Current Procedural Terminology (CPT) codes, which are submitted to insurers for payment.
“Evaluation and Management or E&M visits make up around 40 percent of all Medicare payments under the Physician Fee Schedule, and guidelines have not been updated since 1997—21 years ago,” according to Verma, who added that nearly 750,000 clinicians use these codes. “The requirements often mean that doctors have to cut or paste chunks of information across medical records strictly for billing purposes.”
Verma charged that this documentation process is a “poor use” of clinician time that detracts from direct patient care. “Time spent at the computer documenting and coding for visits is time doctors could be spending with their patients.” In addition, she said that E&M codes “pack the medical records with information that isn’t useful for patient care.”
Verma declared that the proposed changes to the Physician Fee Schedule will “modernize Medicare and restore the doctor-patient relationship” by “streamlining the system of office E&M codes and reducing the requirements for documentation.”
Calling it one of the most significant reductions to provider burden ever undertaken by a U.S. Administration, Verma estimated that the proposal will save about 51 hours of clinic time per clinician annually.
“If you add up the amount of time saved for clinicians across America, in one year from our proposal it would constitute more than 500 years of additional time available for patient care,” she noted. “We’re proposing to move from a system with four different sets of documentation requirements for physicians to a system with just one set of documentation requirements. There will still be four discrete code levels, but the differences will be meaningless. There will be one single set of requirements for documentation and one single payment amount. This will mean less time wasted on copying, pasting, and clicking—and much more time available for patient care.”
As part of the proposed Physician Fee Schedule rule, Verma said CMS will modernize Medicare “by leveraging the latest technology to improve access” to healthcare for beneficiaries. Specifically, the agency is proposing to pay separately for two newly defined physician services—virtual check-ins for patients who can connect with their doctors via telephone or other telecommunications device to decide whether an office visit is needed, as well as enabling clinicians to review patient-transmitted images or video to assess whether a visit is needed.
“This is a big issue for our elderly and disabled populations where transportation can be a barrier to care,” said Verma. However, she emphasized that CMS is “not intending to replace office visits but rather to augment them and create new access points for patients.”
In addition, Verma noted that the agency is also expanding the list of Medicare Part B services that can be delivered via telehealth.
When it comes to the Merit-based Incentive Payment System (MIPS), she indicated that CMS is proposing to remove process-based quality measures from MIPS that providers have told the agency are low value and low priority, as they do not impact health outcomes.
“These changes would save providers collectively an estimated 26,313 hours and more than $2.3 million in 2019,” according to Verma.
CMS is also overhauling the MIPS Advancing Care Information (ACI) performance category and intends to rename it the “Promoting Interoperability” category to support interoperable electronic health records and patient access to their healthcare data.
“We will be changing the focus of this category to reward providers that offer interoperability and provide patients access to their health information,” concluded Verma.
Anders Gilberg, senior vice president for government affairs at the Medical Group Management Association, said MGMA supports the agency’s efforts to reduce regulatory burdens and ensure Medicare quality measurement is meaningful and actionable for medical practices.
However, Gilberg said MGMA is disappointed that CMS plans to continue its “burdensome” 365-day MIPS quality reporting policy rather than 90 consecutive days.
“Reducing the reporting burden would allow more physicians to participate in MIPS and focus the program on rewarding quality care rather than quality reporting,” he argued. “Requiring medical groups to submit excessive amounts of data to the government has little impact on the quality of care delivered to Medicare beneficiaries.”
Further, Gilberg made the case that the agency’s rule “proposes to require physicians to deploy costly EHR upgrades for 2019 and takes further steps toward implementing burdensome appropriate use criteria—at first glance, the rule doesn’t meet MGMA’s definition of administrative simplification.”
A fact sheet on the Calendar Year 2019 Medicare Physician Fee Schedule proposed rule is available here. CMS will accept comments on the proposal until September 10.