CMS E&M Coding Update

Donna White

Donna White

By Donna White, Principal Consultant and Owner of Legacy Consulting Services and Legacy Billing Solutions in Montgomery, Alabama.

Last week we blogged about a proposed change to E&M Coding that would replace E&M levels 2-5 with a single code at a single reimbursable rate. As promised, we want to keep you up to date on the latest regarding this proposed change.

At that time we did not have details about what the new reimbursement rates would be. We now have those details as well as add-on codes for additional reimbursement that are proposed.

There would still be Level 1 rates for new and established patients, mostly to be used by mid-level providers. For an established patient the current reimbursement for a Level 1 is $22 and for new patients, it’s $45. The proposed new rates would be $24 for established patients and $44 for new patients.

For levels 2 – 5, documentation requirements would fall along the current Level 2 E&M code requirements of Expanded Problem Focused (EPF) History (a chief complaint and one to three HPI elements, plus one Review of Systems (ROS)) and an EPF Exam, as well as Straightforward Medical Decision Making (MDM).

The new proposed payment would be $93 for established patients and $135 for new patients. This would tie back into the 1-2% increase or decrease proposed, based on what level of visits you currently use most frequently now.

They are also proposing the following:

A ~$5 add-on payment to recognize additional resources to address inherent complexity in E&M visits associated with primary care services.
A ~$9 add-on payment to recognize additional resources to address inherent complexity in E&M visits associated with certain non-procedural based care
A multiple procedure payment adjustment that would reduce the payment when an E&M visit is furnished in combination with a procedure on the same day.
An add-on payment for a 30-minute prolonged E&M visit. We are currently in the 60-day comment period where feedback from providers is welcomed and encouraged before this becomes a final rule. You can send in your comments and questions via Twitter to @SeemaCMS with the #PatientsOverPaperwork. You can also visit the website set up for the Patients Over Paperwork initiative at: http://go.cms.gov/PatientsOverPaperwork. Provider feedback will be critical in making sure this change benefits not only the patients but the providers treating them as well.

Additionally, make your comments heard by CMS by following the guide below:
1. Go to www.regulations.gov.
2. Enter cms-1693-p in the search window.
3. That will bring up the proposed rule
4. Click on the proposed rule and you will see “Comment Now” on the top right, just under the title of the proposal.

Connect with us on any of the Social Media platforms below and let us know your thoughts on this proposed change, or comment below.

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