From the Washington Office

From the Washington Office: An opportunity to address policymakers on the concerns of Fellows


On March 15, 2018, I had the opportunity to present on behalf of the ACS at a roundtable discussion on Capitol Hill to members of the House Ways and Means Committee on the topic of Medicare red tape relief

The roundtable provided members of this key committee of jurisdiction over Medicare policy the opportunity to hear from representatives from a variety of health care professional organizations on how Congress can improve Medicare to work more effectively and efficiently for both patients and providers. Each group was allotted just three minutes for their presentation. A summary of my presentation is included below:

E/M Documentation Guidelines

The ACS has significant concerns regarding Evaluation and Management (E/M) Documentation Guidelines. Though CMS created the E/M documentation guidelines 23 years ago with the laudable goal of adding structure to the various levels of E/M services, and in an effort to create a sense of equivalency of E/M services across the multitude of specialties, ACS believes the time has come to re-examine and revise these guidelines to be more appropriate in the modern digital information era.

US House Ways and Means Committee

Dr. Patrick V. Bailey speaks at the House Ways and Means Committee.

Physicians first created the medical record with the primary goal of providing an accurate, chronologic record of patient care. Over time, CMS and payers have increasingly utilized the medical record for purposes of determining payment for services. In addition, because the E/M guidelines were introduced when medical records were primarily paper-based, unintended consequences have been amplified resulting in a medical record that is bloated with repetitive and redundant information. Because patient notes in the EHR contain so much duplicative data, it is often difficult to find the relevant information. Much of the necessity for creating these duplicative notes is borne out of the requirements to document information supporting the level of E/M service and the associated payment.

Again, the primary goal of all medical record documentation is to provide an accurate, chronologic record of patient care. That said, the medical record also serves other important goals including communication between providers, data exchange to facilitate clinical decisions, and a legal document. The payment-focused E/M documentation guidelines do not serve any of these objectives.

There must be some level of trust of the provider by the payers. Physicians should have the ability to meet the primary goal of the medical record without being required to repeatedly enter the same information. If a family history is recorded on Monday, there should be no requirement to re-record it on Thursday unless something cogent changes in the interim. ACS believes that documentation should focus on the minimum data elements needed to establish an accurate chronologic record of patient care.

The ACS is prepared to assist in an effort to explore ways to revise the current paper-based E/M documentation guidelines such that they more efficiently and accurately document patient care information in the modern digital era.

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