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CMS Plugs Changes to E/M Coding

— Agency argues that streamlined billing codes will reduce physician burden

MedpageToday

WASHINGTON -- Administration officials sought to explain the nuts and bolts of proposed changes to evaluation and management (E/M) codes during an online panel discussion on Wednesday.

Last week, the Centers for Medicare and Medicaid Services (CMS) proposed several major changes to the Medicare physician fee schedule that the agency believes will greatly reduce some of the paperwork burden physicians face each day.

By making documentation less onerous, CMS says it's giving physicians more time to focus on their patients and to improve their health outcomes.

"If we're serious about improving the quality and access for patients we have to address the concerns of providers on the front lines," CMS Administrator Seema Verma said during Wednesday's webcast.

Under the current system of E/M billing, providers must choose between category levels 1-5. Level 1 is reserved for non-physician services and level 5 is reserved for the most complex patients.

"The differences between levels 2 to 5 are often really difficult to discern and time-consuming to document," said Kate Goodrich, MD, CMS's chief medical officer.

Physicians are required to justify the level they choose by performing certain tasks, for example reviewing a certain number of organ systems during their physical exam, for level 3 and a different number for level 5, she explained.

Also, under current E/M codes, each physician has to redocument a patient's past medical history, family history and social history even if the same histories were already taken and recorded by a previous provider, or during a previous visit.

Under the new proposed rule, the agency "collapsed" the codes between 2 and 5, Goodrich said.

"What we've done is we have proposed to move to a system with minimal documentation requirements for levels 2-5 and one single payment rate," she noted.

In addition, if another provider has already documented a patient's family history, social history and medical history, a physician would not have to redocument that information, Goodrich added.

Physicians would only be required to document any new problems or new aspects to a patient's family history, she clarified.

Asked whether physicians who typically see more complex patients and perform level 4 and 5 care, such as oncologists and cardiologists, would see lower reimbursement, Anand Shah, MD, chief medical officer of the Center for Medicare & Medicaid Innovation, responded that the agency's internal impact analysis "suggests at most an up or down [change in payment] of about 1% to 2%."

Discussants on the webcast also addressed concerns from the medical community over whether making certain elements of documenting patient histories could undermine big data efforts.

To the contrary, Don Rucker, MD, chief of the Office of the National Coordinator for Healthcare Information Technology, noted that one of the big challenges with natural language processing is the glut of templated text -- "antimatter of information," he called it.

In the same way doctors struggle to sort through the clutter to find what's wrong with patients, removing this antimatter also helps computers.

As it is, having the real clinical information buried under boilerplate text "generates safety issues for patients," he said. It's also detrimental to the medical education system.

"The residents, I think, often spend more time worrying about the documentation, than they do the patient," he said.

In all, CMS estimates their proposed changes will save approximately 51 hours of time for each clinician per year.

CMS will be hosting an open forum on Thursday afternoon from 2:00-3:00 p.m. Eastern time to respond to stakeholders' questions about the proposed changes.

The comment period for the proposed rule ends Sept. 10, 2018.