CMS Letter to Providers

On July 16th 2018, anyone subscribed to the CMS Quality Payment Program received an e-mail containing a letter to doctors from Seem Verma, Administrator of the Centers for Medicare and Medicaid Services (CMS). There are some widespread changes proposed in this letter of which you need to be aware.

“Electronic Health Records were supposed to make it easier for you to record notes, and the government spent $30 billion to encourage their uptake. But the inability to exchange records between systems – and the increasing requirements for information that must be documented – has turned this tool into a serious distraction from patient care.”

This is an interesting statement as current MIPS/MACRA reporting has heavily put a focus on Advancing Care Information (ACI) or promoting interoperability requirements between providers and patients. Medicare recognizes the challenge but is also measuring your practices based on the volume of data you share electronically with other providers and patients through data exchange. In June 2018, a recent press release detailed the announcement of the MyHealth EData initiative, making electronic data accessible to patients and able to be shared with any provider they choose. Medicare is leading this initiative with Blue Button 2.0 to allow patients access to their Medicare health data. Verma is pushing private health insurers to follow suit.

Where the big proposed change is coming, however, is in your Evaluation & Management or E&M Codes:

“We’ve proposed to move from a system with separate documentation requirements for each of the 4 levels that physicians use to a system with just one set of requirements, and one payment level each for new and established patients. Most specialties would see changes in their overall Medicare payments in the range of 1-2 percent up or down from this policy, but we believe that any small negative payment adjustments would be outweighed by the significant reduction in documentation burden.”

To be clear, this would mean removing the 5 levels of your 99201 – 99205 and 99211 – 99215, of which you can receive reimbursement at different rates depending on the level of your visit. This would replace those levels with a single visit with a single reimbursement rate. This will effect specialty providers the most, who typically bill at a higher level due to more complex office visits. Now a cardiologist seeing a patient with advanced cardiovascular disease would be reimbursed the same as a primary care physician treating someone with a cold.

The facts are, at this point we don’t have a lot of facts. We don’t know what the new single reimbursement rate would be, so quantifying that “1-2 percent” change in reimbursement is difficult to calculate. However, we will continue to watch for further developments on this issue and make sure you are informed. CMS has stated they welcome your thoughts and proposals on this topic, so if you have concerns, make sure to make your voices heard. Right now, this is a proposed change and nothing official has been done. Provider feedback will be critical in making sure this change benefits not only the patients, but the providers treating them as well.