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Doctors’ dismay at the proposed flattening of evaluation and management (E/M) payments seems to be falling on deaf ears.
More than 170 medical societies and organizations expressed their concern about the new payment structure for E/M codes proposed as part of the 2019 Medicare Physician Fee Schedule (PFS) in comments on the draft rule.
Yet, in the final days of the comment period, Seema Verma, administrator of the Centers for Medicare & Medicaid Services, took to Twitter to defend her agency’s plan.
The controversial proposal would set the payment rate for a level 1 E/M office visit for a new patient at $44, down from the current $45. Payment for levels 2-5 would be $135. Currently, payments for level 2 new patient visits are set at $76, level 3 at $110, level 4 at $167, and level 5 at $211.
For E/M office visits with established patients, the proposed rate would be $24 for level 1, up from the current $22. Payment for levels 2-5 would be $93. Under the current methodology, payments for established patient level 2 visits are set at $45, level 3 at $74, level 4 at $109, and level 5 at $148.
Offsetting the changes in payment are several new proposed add-on codes, according to CMS.
Despite the lower payment for more complex patient care, Ms. Verma touted the scheme’s budget neutrality.
Ms. Verma’s tweets come as medical societies filed their formal complaints on the proposal, mirroring concerns expressed in two letters sent to the agency ahead of the comment deadline. The letters, sent at the end of August and between the two of them signed by more than 170 medical associations, aimed to preempt the comment process. They called for the E/M proposal to be rescinded, claiming that the cuts would reduce access to Medicare services by patients and hurt physicians that treat the sickest patients and those who provide comprehensive primary care because the expected lower reimbursement. One suggested that the changes exacerbate workforce shortages.
In its formal comments, the American Medical Association said that given “the groundswell of opposition from individual physicians and nearly every physician and health professional organization in the country, including the AMA, we ask that CMS set aside its proposal to restructure payment and coding for E/M office and other outpatient visits while an expert physician work group, with input from a broad spectrum of physicians and other health professionals, develops an alternative that could be implemented in 2020.”
The proposed E/M changes “are not an improvement over the current documentation requirements and payment structure. The structure is flawed, and the proposal to reduce payments when E/M services are reported with procedures fails to account for fee schedule reductions that have already been taken on these codes,” according to comments submitted by the American Academy of Dermatology Association.
The American Society of Clinical Oncology said it “supports the Agency’s proposal to reduce documentation burdens for E&M services but pairing it with reductions in payment will negatively impact patient access and should be avoided.”
ASCO also called on the agency to withdraw its proposal to consolidate E/M payments, noting that offsetting payments from add-on codes do “not appear to fully offset the direct and indirect cuts to oncology reimbursement, is ambiguous, and lacks assurances of long-term durability.”
Surgeons “cannot support the collapse of work RVU [relative value unit] values into one single rate under the [physician fee schedule] that would be paid for services using the current CPT codes for level 2 through 5 E/M visits because this single rate is a calculation of several values that were resourced-based, but in and of itself is not a resource-based value. There is no assurance that the underlying math used to derive this single value correctly reflects the resources used to deliver care across a wide spectrum of providers in America,” according to comments submitted by the American College of Surgeons.
ACS also argued that it is “not possible to fully analyze the repercussions and potential distortions to the PFS from these policies individually or taken as a whole during the 60-day comment period.” The comments noted that ACS favors documentation reduction efforts included in the proposal, but urged CMS to delay finalizing any E/M changes until more work can be done in tandem with stakeholders to craft a better solution.
The American College of Cardiology voiced support for the documentation reduction aspects of the E/M proposal but urged CMS to “not finalize any E/M payment changes for 2019. The Agency makes it clear it believes documentation proposals are intrinsically linked to the payment proposals. It is not clear to the ACC exactly why that must be the case.”
ACC also voiced concern over a provision that would halve the least-expensive procedure or the E/M visit code when a physician bills for both simultaneously. “No data are described to indicate that 50% is a correct reduction. Instead, it appears that CMS chose 50% because the reduction is equivalent to the 6.7 million RVUs needed to offset other proposed changes for compressing E/M payment into single levels and allowing use of the new add-on codes.”
A key concern for the American Academy of Family Physicians was collapsing the levels 2 through 5 E/M visits into a single payment level.
Instead, AAFP recommended that CMS work with it and other medical societies to develop new codes and values to ensure proper payment for services. Instead of a primary care add-on code, CMS should increase E/M payments by 15% for services provided “by physicians who list their primary practice designation as family medicine, internal medicine, or geriatrics,” according to the comments.
AAFP is “concerned that the changes included in the proposed rule may harm the quality and cost of care for Medicare beneficiaries,” the comment letter states, adding that it is “possible that beneficiary out-of-pocket costs would increase due to more frequent physician or clinician visits.”
The American College of Rheumatology voiced its support for the focus “on reducing physician burden by simplifying documentation requirements,” but said it had “serious concerns about the changes to evaluation and management (E/M) codes that result in cuts in reimbursement to cognitive specialists for the complex services they provide.” It added that while there is support for the documentation reduction efforts, “we are skeptical that this proposal will simplify the reporting burden on providers in the Quality Payment Program. As proposed, the new plan proposes several ‘add-on’ codes that would likely prevent reduction in audits or documentation.”
The estimated 51 hours per doctor per year of time saved “are insufficient to offset the proposed cuts to reimbursement. For example, if a physician sees around 100 patients a week, this translates to under 40 seconds per patient, which is not a benefit that outweighs the proposed reduction in reimbursement.”
The American College of Physicians voiced its opposition to the E/M proposal, noting that it “strongly believes that cognitive care of more complex patients must be appropriately recognized with higher allowed payment rates than less complex care patients.” ACP said the even with the proposed add-on codes, the proposed changes undervalue cognitive care for the most complex patients.
Doctors’ dismay at the proposed flattening of evaluation and management (E/M) payments seems to be falling on deaf ears.
More than 170 medical societies and organizations expressed their concern about the new payment structure for E/M codes proposed as part of the 2019 Medicare Physician Fee Schedule (PFS) in comments on the draft rule.
Yet, in the final days of the comment period, Seema Verma, administrator of the Centers for Medicare & Medicaid Services, took to Twitter to defend her agency’s plan.
The controversial proposal would set the payment rate for a level 1 E/M office visit for a new patient at $44, down from the current $45. Payment for levels 2-5 would be $135. Currently, payments for level 2 new patient visits are set at $76, level 3 at $110, level 4 at $167, and level 5 at $211.
For E/M office visits with established patients, the proposed rate would be $24 for level 1, up from the current $22. Payment for levels 2-5 would be $93. Under the current methodology, payments for established patient level 2 visits are set at $45, level 3 at $74, level 4 at $109, and level 5 at $148.
Offsetting the changes in payment are several new proposed add-on codes, according to CMS.
Despite the lower payment for more complex patient care, Ms. Verma touted the scheme’s budget neutrality.
Ms. Verma’s tweets come as medical societies filed their formal complaints on the proposal, mirroring concerns expressed in two letters sent to the agency ahead of the comment deadline. The letters, sent at the end of August and between the two of them signed by more than 170 medical associations, aimed to preempt the comment process. They called for the E/M proposal to be rescinded, claiming that the cuts would reduce access to Medicare services by patients and hurt physicians that treat the sickest patients and those who provide comprehensive primary care because the expected lower reimbursement. One suggested that the changes exacerbate workforce shortages.
In its formal comments, the American Medical Association said that given “the groundswell of opposition from individual physicians and nearly every physician and health professional organization in the country, including the AMA, we ask that CMS set aside its proposal to restructure payment and coding for E/M office and other outpatient visits while an expert physician work group, with input from a broad spectrum of physicians and other health professionals, develops an alternative that could be implemented in 2020.”
The proposed E/M changes “are not an improvement over the current documentation requirements and payment structure. The structure is flawed, and the proposal to reduce payments when E/M services are reported with procedures fails to account for fee schedule reductions that have already been taken on these codes,” according to comments submitted by the American Academy of Dermatology Association.
The American Society of Clinical Oncology said it “supports the Agency’s proposal to reduce documentation burdens for E&M services but pairing it with reductions in payment will negatively impact patient access and should be avoided.”
ASCO also called on the agency to withdraw its proposal to consolidate E/M payments, noting that offsetting payments from add-on codes do “not appear to fully offset the direct and indirect cuts to oncology reimbursement, is ambiguous, and lacks assurances of long-term durability.”
Surgeons “cannot support the collapse of work RVU [relative value unit] values into one single rate under the [physician fee schedule] that would be paid for services using the current CPT codes for level 2 through 5 E/M visits because this single rate is a calculation of several values that were resourced-based, but in and of itself is not a resource-based value. There is no assurance that the underlying math used to derive this single value correctly reflects the resources used to deliver care across a wide spectrum of providers in America,” according to comments submitted by the American College of Surgeons.
ACS also argued that it is “not possible to fully analyze the repercussions and potential distortions to the PFS from these policies individually or taken as a whole during the 60-day comment period.” The comments noted that ACS favors documentation reduction efforts included in the proposal, but urged CMS to delay finalizing any E/M changes until more work can be done in tandem with stakeholders to craft a better solution.
The American College of Cardiology voiced support for the documentation reduction aspects of the E/M proposal but urged CMS to “not finalize any E/M payment changes for 2019. The Agency makes it clear it believes documentation proposals are intrinsically linked to the payment proposals. It is not clear to the ACC exactly why that must be the case.”
ACC also voiced concern over a provision that would halve the least-expensive procedure or the E/M visit code when a physician bills for both simultaneously. “No data are described to indicate that 50% is a correct reduction. Instead, it appears that CMS chose 50% because the reduction is equivalent to the 6.7 million RVUs needed to offset other proposed changes for compressing E/M payment into single levels and allowing use of the new add-on codes.”
A key concern for the American Academy of Family Physicians was collapsing the levels 2 through 5 E/M visits into a single payment level.
Instead, AAFP recommended that CMS work with it and other medical societies to develop new codes and values to ensure proper payment for services. Instead of a primary care add-on code, CMS should increase E/M payments by 15% for services provided “by physicians who list their primary practice designation as family medicine, internal medicine, or geriatrics,” according to the comments.
AAFP is “concerned that the changes included in the proposed rule may harm the quality and cost of care for Medicare beneficiaries,” the comment letter states, adding that it is “possible that beneficiary out-of-pocket costs would increase due to more frequent physician or clinician visits.”
The American College of Rheumatology voiced its support for the focus “on reducing physician burden by simplifying documentation requirements,” but said it had “serious concerns about the changes to evaluation and management (E/M) codes that result in cuts in reimbursement to cognitive specialists for the complex services they provide.” It added that while there is support for the documentation reduction efforts, “we are skeptical that this proposal will simplify the reporting burden on providers in the Quality Payment Program. As proposed, the new plan proposes several ‘add-on’ codes that would likely prevent reduction in audits or documentation.”
The estimated 51 hours per doctor per year of time saved “are insufficient to offset the proposed cuts to reimbursement. For example, if a physician sees around 100 patients a week, this translates to under 40 seconds per patient, which is not a benefit that outweighs the proposed reduction in reimbursement.”
The American College of Physicians voiced its opposition to the E/M proposal, noting that it “strongly believes that cognitive care of more complex patients must be appropriately recognized with higher allowed payment rates than less complex care patients.” ACP said the even with the proposed add-on codes, the proposed changes undervalue cognitive care for the most complex patients.
Doctors’ dismay at the proposed flattening of evaluation and management (E/M) payments seems to be falling on deaf ears.
More than 170 medical societies and organizations expressed their concern about the new payment structure for E/M codes proposed as part of the 2019 Medicare Physician Fee Schedule (PFS) in comments on the draft rule.
Yet, in the final days of the comment period, Seema Verma, administrator of the Centers for Medicare & Medicaid Services, took to Twitter to defend her agency’s plan.
The controversial proposal would set the payment rate for a level 1 E/M office visit for a new patient at $44, down from the current $45. Payment for levels 2-5 would be $135. Currently, payments for level 2 new patient visits are set at $76, level 3 at $110, level 4 at $167, and level 5 at $211.
For E/M office visits with established patients, the proposed rate would be $24 for level 1, up from the current $22. Payment for levels 2-5 would be $93. Under the current methodology, payments for established patient level 2 visits are set at $45, level 3 at $74, level 4 at $109, and level 5 at $148.
Offsetting the changes in payment are several new proposed add-on codes, according to CMS.
Despite the lower payment for more complex patient care, Ms. Verma touted the scheme’s budget neutrality.
Ms. Verma’s tweets come as medical societies filed their formal complaints on the proposal, mirroring concerns expressed in two letters sent to the agency ahead of the comment deadline. The letters, sent at the end of August and between the two of them signed by more than 170 medical associations, aimed to preempt the comment process. They called for the E/M proposal to be rescinded, claiming that the cuts would reduce access to Medicare services by patients and hurt physicians that treat the sickest patients and those who provide comprehensive primary care because the expected lower reimbursement. One suggested that the changes exacerbate workforce shortages.
In its formal comments, the American Medical Association said that given “the groundswell of opposition from individual physicians and nearly every physician and health professional organization in the country, including the AMA, we ask that CMS set aside its proposal to restructure payment and coding for E/M office and other outpatient visits while an expert physician work group, with input from a broad spectrum of physicians and other health professionals, develops an alternative that could be implemented in 2020.”
The proposed E/M changes “are not an improvement over the current documentation requirements and payment structure. The structure is flawed, and the proposal to reduce payments when E/M services are reported with procedures fails to account for fee schedule reductions that have already been taken on these codes,” according to comments submitted by the American Academy of Dermatology Association.
The American Society of Clinical Oncology said it “supports the Agency’s proposal to reduce documentation burdens for E&M services but pairing it with reductions in payment will negatively impact patient access and should be avoided.”
ASCO also called on the agency to withdraw its proposal to consolidate E/M payments, noting that offsetting payments from add-on codes do “not appear to fully offset the direct and indirect cuts to oncology reimbursement, is ambiguous, and lacks assurances of long-term durability.”
Surgeons “cannot support the collapse of work RVU [relative value unit] values into one single rate under the [physician fee schedule] that would be paid for services using the current CPT codes for level 2 through 5 E/M visits because this single rate is a calculation of several values that were resourced-based, but in and of itself is not a resource-based value. There is no assurance that the underlying math used to derive this single value correctly reflects the resources used to deliver care across a wide spectrum of providers in America,” according to comments submitted by the American College of Surgeons.
ACS also argued that it is “not possible to fully analyze the repercussions and potential distortions to the PFS from these policies individually or taken as a whole during the 60-day comment period.” The comments noted that ACS favors documentation reduction efforts included in the proposal, but urged CMS to delay finalizing any E/M changes until more work can be done in tandem with stakeholders to craft a better solution.
The American College of Cardiology voiced support for the documentation reduction aspects of the E/M proposal but urged CMS to “not finalize any E/M payment changes for 2019. The Agency makes it clear it believes documentation proposals are intrinsically linked to the payment proposals. It is not clear to the ACC exactly why that must be the case.”
ACC also voiced concern over a provision that would halve the least-expensive procedure or the E/M visit code when a physician bills for both simultaneously. “No data are described to indicate that 50% is a correct reduction. Instead, it appears that CMS chose 50% because the reduction is equivalent to the 6.7 million RVUs needed to offset other proposed changes for compressing E/M payment into single levels and allowing use of the new add-on codes.”
A key concern for the American Academy of Family Physicians was collapsing the levels 2 through 5 E/M visits into a single payment level.
Instead, AAFP recommended that CMS work with it and other medical societies to develop new codes and values to ensure proper payment for services. Instead of a primary care add-on code, CMS should increase E/M payments by 15% for services provided “by physicians who list their primary practice designation as family medicine, internal medicine, or geriatrics,” according to the comments.
AAFP is “concerned that the changes included in the proposed rule may harm the quality and cost of care for Medicare beneficiaries,” the comment letter states, adding that it is “possible that beneficiary out-of-pocket costs would increase due to more frequent physician or clinician visits.”
The American College of Rheumatology voiced its support for the focus “on reducing physician burden by simplifying documentation requirements,” but said it had “serious concerns about the changes to evaluation and management (E/M) codes that result in cuts in reimbursement to cognitive specialists for the complex services they provide.” It added that while there is support for the documentation reduction efforts, “we are skeptical that this proposal will simplify the reporting burden on providers in the Quality Payment Program. As proposed, the new plan proposes several ‘add-on’ codes that would likely prevent reduction in audits or documentation.”
The estimated 51 hours per doctor per year of time saved “are insufficient to offset the proposed cuts to reimbursement. For example, if a physician sees around 100 patients a week, this translates to under 40 seconds per patient, which is not a benefit that outweighs the proposed reduction in reimbursement.”
The American College of Physicians voiced its opposition to the E/M proposal, noting that it “strongly believes that cognitive care of more complex patients must be appropriately recognized with higher allowed payment rates than less complex care patients.” ACP said the even with the proposed add-on codes, the proposed changes undervalue cognitive care for the most complex patients.