AAFP Issues Summary of Proposed 2019 Medicare Fee Schedule

Changes to E/M Code Documentation, Payment Among CMS' Proposals

July 24, 2018 02:36 pm News Staff – The AAFP has released its initial summary of the proposed 2019 Medicare physician fee schedule which, for the first time, also includes recommended changes that would affect CMS' Quality Payment Program in 2019.

The fee schedule was released for public review on July 12 and will be officially published in the Federal Register on July 27.

Family physicians are invited to take a look at the Academy's two-page summary but should keep in mind that it's merely a precursor to a much lengthier and detailed formal comment letter the AAFP will submit by the agency's Sept. 10 deadline. As in years past, that comment letter will urge numerous changes favorable to family medicine.

CMS typically reviews stakeholder comments before issuing a final fee schedule rule late in the fall.

Proposals designed to change evaluation and management (E/M) documentation and payment immediately grabbed the AAFP's attention because of the widespread use of these codes in family medicine practices.

According to the summary, CMS proposes simplifying E/M coding by blending CPT codes 99202-99205 -- codes that cover new patient office visits levels two through five -- into a single payment of $135.

Similarly, CMS proposes blending established patient office visits levels two through five that currently are covered by CPT codes 99212-99215 into a single payment of $93.

CMS also proposes new rules that would, among other things,

decrease documentation requirements for patient history and exam by focusing on interval history since the last patient exam,
save physicians time by not requiring them to re-enter information into the medical record but instead allowing them to simply review and verify certain information entered by ancillary staff or beneficiaries,
institute a payment reduction of 50 percent, applied to the lower paid of two services, when physicians report an E/M service and a procedure on a single day,
establish new CPT codes and payment for remote monitoring of patients and interprofessional consultations,
identify misvalued services,
implement payment for care management services and communication technology-based services provided in rural health clinics and federally qualified health centers, and
further enhance the existing appropriate use criteria for advanced diagnostic imaging policy.

Regarding changes related to the QPP's Merit-based Incentive Payment System, CMS proposes to, among other things,

require eligible clinicians to move to 2015-edition certified electronic health record technology; and
retain, but revise, the low-volume threshold, as previously recommended by the AAFP, so that eligible clinicians can opt in if they meet one or two, but not all, of the low-volume threshold criteria.

Additionally, CMS proposes establishing new category weighting for the 2019 performance year that would set

quality at 45 percent,
cost at 15 percent,
promoting interoperability at 25 percent, and
improvement activities at 15 percent.