New CMS Proposed Rule On E/M Coding Could Reduce Podiatry Reimbursement

The Centers for Medicare and Medicaid Services (CMS) on July 27 released its plan to reduce paperwork and improve patient care.¹ What CMS is proposing is to combine the evaluation and management (E/M) codes—that currently have four to five levels of codes with specific documentation requirement for each level of code and four to five levels of reimbursement—to a single payment level for a new patient and a single payment level for an established payment. The CMS notes this could have an impact on the 40 percent of Medicare payments that are for E/M services

As CMS Administrator Seema Verma, MPH, wrote in a July 17 letter previewing the proposal: “We’ve proposed to move from a system with separate documentation requirements for each of the four 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.”²

This proposal is open for comment until September 10. Most of us would not be opposed to reduced paperwork. I have read that although the reduction in documentation could save a minute or two per appointment since many of us use an EMR, the reduced reimbursement would not offset or reduce the burden CMS seeks to help us manage. The rule change will definitely reduce the reimbursement we will see for the higher level of visits that are often required to take care of more complicated patients. 

As Policy and Medicine points out, obstetricians and gynecologists would experience the biggest potential increase of 4 percent from the proposed E/M changes.³ In contrast, podiatry and dermatology would take the biggest hit with 4 percent decrease.

The CMS argues the negative financial impacts will be offset by the reduction in administrative burdens as outlined in the proposed rule. As noted, this reduction of administrative activity would be miniscule per patient visit and a reduction of paperwork involved could not compensate for reductions of payment received.

CMS believes that podiatrists would be seeing a 12 percent increase in reimbursement throught this change, and that hand surgeons and dermatologists would see a 4 to 6 percent increase with the code consolidation. With this information, CMS has proposed to release G codes for podiatrist to use specifically for our E/M services with reimbursements reduced further.

The American Podiatric Medical Association (APMA) is taking a very proactive approach to this new proposal to protect patients and practitioners alike. I strongly encourage my colleagues to share their views on this E/M coding change prior to next month’s September 10 due date for comments. You can comment at https://apma.quorum.us/campaign/12828/.

References

1. Federal Register. Available at https://www.federalregister.gov/documents/2018/07/27/2018-14985/medicare-program-revisions-to-payment-policies-under-the-physician-fee-schedule-and-other-revisions .

2. Centers for Medicare and Medicaid Services. Available at https://www.cms.gov/Outreach-and-Education/Outreach/FFSProvPartProg/Provider-Partnership-Email-Archive-Items/2018-07-17-eNews-SE.html . Published July 17, 2018.

3. Sullivan T. CMS proposed evaluation and management E/M documentation and payment changes are sparking backlash and may hurt patients. Policy and Medicine. Available at https://www.policymed.com/2018/07/cms-proposed-evaluation-and-management-e-m-documentation-and-payment-changes-are-sparking-backlash-and-may-hurt-patients.html . Published July 23, 2018.

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