CMS Delays Implementing Revised E/M Visit Policies

On November 1, 2018, the Centers for Medicare & Medicaid Services (CMS) announced that certain policy changes in the Medicare Physician Fee Schedule relating to the documentation, coding and payment structure of Evaluation and Management office/outpatient visits will now be delayed until 2021. The changes were originally set to go into effect on January 1, 2019. CMS issued a Fact Sheet summarizing the changes.

CMS made the decision to postpone the consolidation of Levels 2 through 4 office/outpatient E/M visits into a single payment rate for both new and established patients after many healthcare providers expressed concern regarding the change. Another postponed change will permit providers to choose to document E/M office/outpatient visit Levels 2 through 5 using medical decision-making or time instead of applying the current 1995 or 1997 E/M documentation guidelines.

In the meantime, in 2019 CMS will implement certain documentation policies under the new rule that are intended to relieve physicians from having to provide duplicative notations in patient medical records. According to CMS’s Fact Sheet, for established patient office/outpatient visits, to the extent that information is already contained in the medical record, healthcare providers will now have the flexibility to focus their documentation on what has changed since the last visit, or on the pertinent items that have not changed.

In a CMS Press Release from July 12, 2018, CMS Administrator Seema Verma referred to the changes as a delivery on the “pledge to put patients over paperwork.”