More Proposed CMS changes to Reimbursement

In the recent weeks, we have seen dramatic proposals from CMS regarding policy changes regarding reimbursement. If you missed the previous articles on E&M Coding and Reimbursement Changes, click here and here.

On July 27th, a new proposal has been made for 2019.

We have heard some client complaints that UHC has begun reducing reimbursement by paying 50% for services with the 25 modifier. This is the modifier used when a separately identifiable E&M service is done on the same day of a procedure or service. For most payors, including Medicare, this has been fully reimbursable.

Often done for patient convenience and for physician efficiency, CMS is proposing to reduce reimbursement by 50% (the national equivalent of $47-$68 on a sick visit encounter). This reduction model was initially introduced and has only been applied to surgical procedures when multiple procedures are performed during the same surgical event. This is the first time CMS is proposing to make this reduction on E&M visits the same day as procedures.

Now is the time to speak up if you do not agree with this proposal! The comment period expires September 10, 2018, so time is running out!

How can your voice be heard?

1. Go to

2. Enter CMS-2018-0076 in the search window

3. Look for the Physician Fee Schedule FR dated July 27, 2018 about halfway down and click the “COMMENT” button.

Individual comments make the most impact, so make sure to take the time today to let your voice be heard!

If you haven’t been able to leave your comments yet regarding the E&M reimbursement change either, here are instructions on how to do so today:

1. Go to

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.

Donna White

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

1 thought on “More Proposed CMS changes to Reimbursement”

  1. Pingback: 2018: A Year in Review | Legacy Consulting Services

Leave a Comment

Your email address will not be published. Required fields are marked *