The Centers for Medicare and Medicaid Services (CMS) recently released the Medicare Physician Fee Schedule Proposed Rule for 2019 (#MPFS2019).
As a refresher: The #MPFS2019 outlines how the Centers for Medicare and Medicaid Services (CMS) intends to update Medicare payment policies for the year ahead. Every summer, reviewing and providing feedback to @CMSgov on #Medicare payment is a major focus for our AGS experts, regulatory consultants, and policy staff. This year, for the first time, @CMSgov combined the #MPFS2019 and what is normally a separate rule regarding plans to update the Quality Payment Program (#QPP). The result is a 1,400-page proposal which we’re currently wading through.
Nonetheless, our team did quickly zero in on proposals for extensive changes to the documentation requirements and payment methodology for outpatient/office evaluation and management (or E/M) codes (99201-99215) as an area of concern for the AGS, its members, and the older Americans you serve.
As background for readers who don’t closely follow Medicare payment guidelines, Medicare’s E/M system currently has 5 levels for office visits, each with different documentation requirements that we, along with others, have noted can be confusing and burdensome. In conjunction with a proposal to reduce the documentation requirements in the #MPFS2019, CMS is also proposing to reduce the number of payment levels from five to two, with current-levels 2-5 covered by a single payment of $135 for new patients and $93 for existing patients. This chart illustrates that proposal:
CMS also is proposing to create G-codes for which primary care ($5.71) and selected specialties ($13.70; not geriatrics) can also bill when providing non-procedural care to complex older Americans. However, providers can only use one add-on code. We believe it’s unlikely that the primary care G-code will make up lost revenue for most our members since the sum including the add-on code is still less than reimbursement for patients currently classified at level 4 or higher in the chart above.
Full Stop: Much of the savings from this proposal appears to come at the expense of care for the most complex Medicare beneficiaries—older Americans with multiple chronic conditions.
We worry that the proposed changes could reduce access to the kind of care that we all will need as we grow older—the care that #geriatrics health professionals provide every day to the older Americans they serve.
Although our team is still reviewing the full 1,400-page proposed rule, we have already begun work on how best to address the changes that CMS is proposing to E/M. This includes working with a coalition of like-minded professional societies on a joint letter, seeking meetings with CMS, and reaching out to members of Congress on how these proposals could impact their constituents. It also means identifying ways that CMS might move forward on its goal of simplifying E/M documentation without negatively impacting the care that our members provide by reducing payment for that care.
Our team has prepared a summary for the E/M proposal in the #MPFS2019, which is attached here for your review. We are working on a summary of the entire rule which we will share with you soon. We’ll also be providing updates on our work via the weekly AGS listserv and also on this blog. As our work progresses, we may be reaching out to some AGS members for assistance with Congress or to glean your thoughts on how these changes might impact your practice.
If you are on Twitter, I encourage you to share your thoughts and questions with @CMSGov and CMS Administrator @SeemaCMS directly and respectfully using the hashtags #MPFS2019 #geriatrics #OlderAmericans and #Medicare.