Hi, all.
Yesterday, the Centers for Medicare & Medicaid Services (CMS) released the final 2019 Medicare Physician Fee Schedule, which outlines all the payment policies, payment rates, and quality provisions for Medicare services to be provided in the next calendar year. The rule also include updates made to the Quality Payment Program (QPP) for Year 3.
There were several changes proposed for the Medicare Physician Fee Schedule next year that had the AGS concerned--principal among them revisions to reimbursement for evaluation and management (E/M) services (described in more detail below). The AGS spent much of the summer and early fall compiling feedback for CMS, engaging stakeholders, leading a multispecialty coalition, and seeking meetings with CMS and leaders on Capitol Hill. Our recent JAGS special article outlined our efforts and comments on CMS’s proposed rule, and the information included therein still provides helpful context for understanding the final rule, particularly since it looks like many of our concerns were addressed directly by CMS (thanks in no small part to advocacy from members, I'm sure.).
The final rule itself is 2,200+ pages long, so it’ll take some time for our AGS staff and experts to digest it in full. While they do, here are two important highlights to note:
E/M Payment Proposal Delayed to 2021: CMS committed to delay the collapse of E/M service codes until 2021. In their proposed rule released in July, CMS had suggested collapsing E/M levels 2-5 for new and established patients, which would have reimbursed for care without regard for complexity or the time needed to address patient priorities. We’re still assessing plans for the delay in greater detail, but we’re optimistic that this will give stakeholders like the AGS more of an opportunity for input into proposed revisions.
Revisions to E/M Documentation Guidelines Implemented: CMS also committed to changes we were happy to see in their initial proposal, namely around simplifying E/M documentation requirements.
We’ll be providing more updates once our experts have a chance to finish their deeper dive. For now, here are some additional tools to help bring you up-to-speed:
- CMS released this fact sheet on the 2019 Medicare Physician Fee Schedule final rule.
- CMS released documents outlining Year 3 of the Quality Payment Program (QPP) (also part of the final rule)
- If you’re looking for some light reading (or you’re particularly bold), you can read the full final rule here.
Best,
Nancy