Open Letter to CMS on Proposed E/M Rule

The Patient-Centered Evaluation and Management Services Coalition submitted an open letter to Congress in September sharing their concerns over the new proposed 2019 rule. For more on the details of this rule, check out Part 1 and Part 2.

Their concerns are not only over the new payment structure but the documentation guidelines as well:

“We have significant concerns that the coding and payment aspects for the Rule, as currently framed, will have unintended consequences that will negatively impact patient access to appropriate care and should not be made final this year. For example, CMS proposes new codes that, while well-intentioned, are vague and could create new documentation burdens for practitioners.”

As they go on to detail, these changes are going to require significant changes to electronic health records that vendors will not have time to implement prior to the Rule going into effect January 2019.

Their suggestion is to hold off at least a year for additional modeling to “obtain more accurate estimates of the impacts of payment changes on medical practices and implications for patient care.” The coalition has even engaged an independent consultant to perform additional analysis of the changes that could be brought about by this proposal.

The Coalition even provides several suggested guidelines to improve the Patients Over Paperwork proposed rule:

“1. Allow physicians the option to document office visits based solely on the level of medical decision-making or the face-to-face time for the visit as an alternative to the current guidelines.
2. Limit required documentation of an established patient’s history to the interval history since the patient’s previous visit for physicians who choose to continue using the current guidelines.
3. Eliminate the requirement for physicians to re-document information included by practice staff or the patient in the medical record.
4. Eliminate the prohibition on billing same-day visits by practitioners of the same group and specialty.
5. Eliminate the requirement to document justification for a home visit instead of an office visit.”

The Coalition is comprised of specialties of all kinds – from Allergy, Hospice, Ophthalmology, Nephrology, Psychiatry and many more. For the full letter to Congress, click here.

Donna White

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