Two Clicks To Defend Podiatry And Your E/M Fee Schedule

I have never used this space for something like this before but our profession has not seen such a threat in my career. Please use the links at the bottom of this blog to act.

You may have already heard that the Centers for Medicare and Medicaid Services (CMS) has released a proposed rule that, if finalized, would require podiatrists to use different evaluation and management (E/M) codes than all other Medicare physicians. Those podiatry-specific codes would reimburse at a significantly lower rate.

The good news is this is only a proposed rule and CMS has publicized that it wants to receive comments from stakeholders. The other good news is you can make your voice heard by clicking on two links in this blog post. The three main issues pertinent to podiatrists in the Proposed Rule are as follows …

1. The CMS proposes to consolidate reimbursement for office-based and outpatient E/M visit levels 2 through 5 (i.e., CPT codes 99202 through 99205 for new patients and CPT codes 99212 through 99215 for established patients) into a singular flat-rate payment for new patients and established patients, respectively, regardless of which code you bill. Documentation requirements would be the same as they currently are for level 2 codes (99202 or 99212 as applicable).
2. While the payment changes described above would apply to all other Medicare physicians, CMS proposes to single out podiatric physicians with new separate “podiatric E/M codes” developed by CMS. These codes would require the same documentation and reimburse at a significantly lower rate despite being the same evaluation and management services that our allopathic and osteopathic colleagues furnish.

3. The CMS proposes to apply the Multiple Procedure Payment Reduction (MPPR) to services that accompany a separately identifiable E/M.

Thankfully, the American Podiatric Medical Association (APMA) has been all over this since it was announced and is advocating for all podiatrists in many ways, including:

• Submitting its own comment letter to CMS
• Meeting with CMS directly
• Engaging congressional allies
• Engaging with external stakeholders
• Collaborating with other societies
• Facilitating submission of comment letters by component and affiliate societies
• Facilitating the submission of comment letters by patients
• And much, much more!

There are three very important things that every podiatrist in the country and anyone who has any dealing with podiatry must do if you have not already!

1. Go to the APMA eAdvocacy website https://apma.quorum.us/campaign/12828/ . The APMA provides a sample letter for you to help you write to CMS but encourages you to add any of your own constructive thoughts. If you have not previously used the APMA's new eAdvocacy site, you must register using either your Facebook account or by manually entering the information requested. You do not need to be an APMA member to use this.

2. Ask your patients and any other interested parties to submit comments from the their perspective. The APMA has made this very easy by providing a simple link to allow patients any anyone else to do this along with a templated letterand they can add their own thoughts to this letter if they wish. Please share this link with your patients and any interested parties to facilitate their letters: https://apma.quorum.us/register/?embedded=true& .

3. Share the link in #1 with every podiatrist you know and ask them to participate. Share the link in #2 with your staff, family, friends and anyone who has an interest in protecting what is fair and best for the care that we provide.

This affects more than just podiatrists. If you are reading this, the effects of not stopping the Proposed Rule can impact you as well. Industry, publishers, consultants, editors, billers, writers, coders, etc., please use the above links to act.

Dr. Lehrman is a consultant to the APMA Health Policy and Practice Department, serves as an expert panelist on Codingline, and is a Fellow of the American Academy of Podiatric Practice Management (AAPPM). Follow him on Twitter @DrLehrman.

Acknowledgement

The APMA produced much of this information.

Reference

1. Medicare Program; Revisions to Payment Policies under the Physician Fee Schedule and Other Revisions to Part B for CY 2019; Medicare Shared Savings Program Requirements; Quality Payment Program; and Medicaid Promoting Interoperability Program. Available at https://s3.amazonaws.com/public-inspection.federalregister.gov/2018-14985.pdf?embedded=true .