Sweeping reductions to documentation included in Medicare fee schedule proposal


Doctors could spend less time with their EHRs under Medicare’s proposed physician fee schedule for 2019.

Seema Verma CMS

Seema Verma

The sweeping proposal also would improve Medicare telemedicine opportunities and update portions of the Quality Payment Program and the Medicare Shared Savings Program, according to documents posted online July 12. There would also be more opportunities to be paid for telemedicine services under the proposed rule, released by the Centers for Medicare & Medicaid Services online July 12 and scheduled for publication July 27 in the Federal Register.

“We are streamlining the system of office E&M codes and reducing the requirements for documentation,” CMS Administrator Seema Verma said during a July 12 press conference.

The proposal would condense all four levels of E&M coding to one level, with one payment – there would no longer be higher payments provided for high levels.

While the change could reduce payments to specialists who generally bill only at the highest level for E&M visits, that difference should be made up in the additional time physicians should have to see patients, according to a fact sheet on the proposed physician fee schedule.

“We estimate that this proposal would save approximately 51 hours of clinic time per clinician per year,” Ms. Verma said, or an additional 500 years of time available for patient care across the system.

The proposed schedule also would expand the list of services that qualify for telemedicine payments and would add payments for virtual check-ins via phone or other communication technologies such as Skype, paying clinicians for time spent reviewing patient photos submitted via text or e-mail.

More time savings could come from proposed reductions to the documentation required to qualify for bonus payments under the Merit-based Incentive Payment System (MIPS) track of the Quality Payment Program.

CMS proposes to remove 34 process measures that are considered to be low-value or low-priority, Ms. Verma said, noting that most physicians are doing these measures but seeing no meaningful difference in the performance that would differentiate payment under the program.

The proposed update continues on with the MyHealthEData initiative by supporting greater patient access to their individual health records. Ms. Verma said that the agency will “reward providers that offer interoperability and provide patients access to their health information.”

While the proposal would not change most of the thresholds for participating MIPS – physicians still would be exempted if they bill Medicare $90,000 or less annually and see 200 or fewer Medicare patients – they also would be exempted if they perform 200 or fewer services under Medicare fee schedule. However, the agency is proposing for the first time to allow physicians to opt-in to the MIPS program if they are prepared to meet the program’s requirements, according to a fact sheet on the proposed changes to QPP.

CMS also is proposing changes to how it pays for new drugs administered in the physician office under Medicare Part B. The proposal would reduce reimbursement for drugs that have not yet been on the market long enough to establish an average sales price from wholesale acquisition cost (WAC) plus 6% to WAC plus 3%, potentially saving money for both patients and Medicare.

The agency also asked for information related to price transparency as part of the proposal. It is looking for perspectives on whether providers and suppliers can and should be required to provide charge and payments information, for health care services and out-of-pocket costs, as well as what data elements would be most useful to consumers to promote price shopping.

Comments on the proposed rule will be accepted at www.regulations.gov until Sept. 10.


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