CMS has proposed to reward physicians who consult electronically/by phone with other physicians in 2019. The agency also proposed starting to pay physicians to review photos that patients text/e-mail to them. Telehealth is now playing a new role for appropriating medical services and giving providers the helping hand to create connected care platforms!nnUnderstand Medicare telehealth requirements—including coverage, coding, and documentation rules—and ensure your telehealth program and claims comply.nnBank on TCI’s all-new, end-to-end 
As many of us reflect on the things in life we are thankful for, all of us at Welter Healthcare Partners would like to say Happy Thanksgiving to our clients, business partners, families and friends! We are extremely grateful for each of you and appreciate your continuous support!nnIn observance of the holiday, we will be closed on Thursday, November 22nd to give our employees time to enjoy the day with their loved ones. We hope you have a wonderful Thanksgiving!nnFederal CMS Agrees to Improvements in E/M Documentation and Delays “Collapse” of Levels
In the 2019 proposed rule on the Medicare Physician Fee Schedule (PFS), the Centers for Medicare and Medicaid Services (CMS) proposed revisions to the E/M documentation guidelines intended to reduce administrative burden on physicians. In addition, the federal CMS proposed coding and payment changes to new and established office visit services. The AMA led the development of a joint comment letter from 170 physician and other health professional organizations calling for the agency to finalize several proposed changes to E/M documentation guidelines for CY2019.nn“The AMA is pleased to report that the federal CMS is implementing the documentation policies, which will significantly reduce administrative burden and allow all physicians to spend more time with their patients,” the AMA stated. The agency has also acknowledged the work of the AMA’s CPT/RUC Workgroup on E/M and has postponed any coding and payment-related changes for E/M office visit services until CY2021. This delay in implementation will allow the CPT Editorial Panel to consider the workgroup’s proposal in February 2019 prior to prompt consideration by the AMA/Specialty Society RVS Update Committee (RUC).nnOn page 584 of the rule, the federal CMS states:nn“We recognize that many commenters, including the AMA, the RUC, and specialties that participate as members in those committees, have stated intentions of the AMA and the CPT Editorial Panel to revisit coding for E/M office/outpatient services in the immediate future. We note that the 2-year delay in implementation will provide the opportunity for us to respond to the work done by the AMA and the CPT Editorial Panel, as well as other stakeholders. We will consider any changes that are made to CPT coding for E/M services, and recommendations regarding appropriate valuation of new or revised codes.”nnRemoving restrictions on E/M codingnnThe federal CMS finalized several changes to E/M documentation guideline which were strongly supported by the AMA and other members of the federation.n
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- The requirement to document medical necessity of furnishing visits in the home rather than office will be eliminated.
- Physicians will no longer be required to re-record elements of history and physical exam when there is evidence that the information has been reviewed and updated.
- Physicians must only document that they reviewed and verified information regarding chief complaint and history that is already recorded by ancillary staff or the patient.
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nThese changes will take effect Jan. 1, 2019.nnThe original proposal condensing office visit payment amounts and documentation requirementsnnIn the 2019 proposed rule, the federal CMS proposed to implement a single payment rate for level 2 through level 5 office visits and to reduce documentation requirements for this collapsed payment to that of a level 2 CPT visit code. The agency proposed to continue to use existing CPT structure for office visit codes 99201-99215, though proposed to change guidelines and only enforce certain aspects of the CPT structure by allowing physicians to choose the method of documentation, among the following options:n
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1995 or 1997 Evaluation and Management Guidelines for history, physical exam and medical decision making (current framework for documentation).- Medical decision-making only.
- Physician time spent face-to-face with patients.
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nThe federal CMS had also proposed an add-on code to each office visit performed for primary care purposes and an add-on code for specialties with inherently complex E/M visits. The agency relayed that commenters overwhelmingly opposed this proposed payment collapse. The federal CMS will not finalize the proposal for CY 2019.nnOther coding/payment proposals related to E/MnnThe following policies were also opposed by the AMA and will not be implemented by the federal CMS:n
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- Payment reductions by 50 percent for office visits that occur on the same date as procedures (or a physician in the same group practice). The AMA brought attention to the fact that duplicative resources have already been removed from the underlying procedure through the current valuation process.
- In addition, the federal CMS proposed to no longer allow for podiatry to report CPT codes 99201-99215 and instead would use two proposed G-codes for podiatry office visits as well as a new prolonged service code that would have been implemented to add-on to any office visit lasting more than 30 minutes beyond the office visit (i.e., hour-long visits in total).
- Condensed practice expense payment for the E/M office visits, by creating a new indirect practice expense category solely for office visits, overriding the current methodology for these services by treating Office E/M as a separate Medicare Designated Specialty. This change would also have resulted in the exclusion of the indirect practice costs for office visits when deriving every other specialty’s indirect practice expense amount for all other services that they perform, which would have resulted in large changes in payment for many specialties (i.e., a greater than 10 percent payment reduction for chemotherapy services).
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nProposals for CY 2021 and the CPT/RUC Workgroup on E/MnnFor CY 2021, the agency conveyed its intention to propose two basic payment rates for office visit services, one for straightforward visits and another for complex visits. In addition, the federal CMS noted their intention to propose add-on codes for primary care and inherently complex specialty E/M visits.nnCMS noted they will also consider input from the AMA and the CPT/RUC Workgroup on E/M as well as input from across the medical community. In response to the Medicare Proposed Rule, the chairs of the AMA CPT Editorial Panel and the AMA/Specialty Society Relative Value Update Committee (RUC) formed the CPT/RUC Workgroup on E/M to:n
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- Capitalize on the CMS proposal and solicit suggestions feedback on the best coding structure to foster burden reduction, while ensuring appropriate valuation.
- Consider a code change application to be submitted to the CPT Editorial Panel for consideration at their Feb. 7-9, 2019 meeting.
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nThe workgroup is comprised of 12 experts in both coding and valuation (six members each from each of the CPT and RUC processes). In addition to the 12 workgroup members, roughly 300 additional stakeholders from national medical specialty societies, the federal CMS and other health-care-related organizations have participated.nnThe workgroup has expressed their appreciation of the agency’s efforts to address long-standing issues with E/M services and has worked tirelessly over the past several months to establish a long-term, stable CPT coding solution. Listening to the federal CMS and other stakeholder concerns, the workgroup has worked to build consensus around modernizing the office and outpatient E/M CPT codes to simplify the documentation requirements and better focus code selection around medical decision-making and physician time. The workgroup proposal will be formally reviewed by the national medical specialty societies via the CPT Advisory Committee process. The CPT Editorial Panel will review the proposal, and related comments, at the Feb. 7-9, 2019 meeting.nnClick here for more information on the Medicare PFS portion of rule.nnOriginal article posted on cms.org.
Changes to the 2019 PFS include the following:n
Lopez said the ACP has reservations about paying level four visits, the second most complex visit, at the same amount as levels two and three. “Internists appreciate CMS’ decision not to finalize changes in payments for evaluation and management services until 2021. We are hopeful that the additional two calendar years leave time for physicians and other health care stakeholders to work together with regulators to develop and test alternatives that preserve higher payment for more complex, cognitive care,” she said.nnThe American Medical Association also supported with the delay. “The AMA also is grateful that the Administration is not moving forward in 2019 with the payment collapse of E/M codes,” said AMA President Barbara L. McAneny, MD, in a statement. “A two-year window for implementation of the proposal will give the AMA-convened workgroup—comprised of physicians and other health professionals —time to make recommendations on this complicated topic.”nnOverall, William S. Mayo, DO, president of the American Osteopathic Association, said he is pleased CMS listened to commenters’ feedback. “The AOA is grateful that CMS heeded the concerns expressed by practicing physicians about the proposed rule and looks forward to advancing the dialogue on how physician payment policy can be modified for the betterment of both physician practice and the patients we care for,” Mayo said in a statement.nnOriginal 
CMS has issued its final 2019 rule for both the Physician Fee Schedule (PFS) and the Quality Payment Program (QPP), which includes the Merit-based Incentive Payment System (MIPS).nn“Today’s rule finalizes dramatic improvements for clinicians and patients and reflects extensive input from the medical community,” CMS Administrator Seema Verma said in a statement. “Today’s rule offers immediate relief from onerous requirements that contribute to burnout in the medical profession and detract from patient care. It also delays even more significant changes to give clinicians the time they need for implementation and provides time for us to continue to work with the medical community on this effort.”nnUnder the final QPP rule, MIPS-eligible clinicians will be required to use a 2015 Edition certified EHR as of Jan. 1, 2019. CMS says this change is necessary so patients can more easily access their data and information can more easily be shared among doctors and other providers. But Ana Maria Lopez, MD, MACP, president of the American College of Physicians, has concerns, especially with the short implementation timeline. “Rushing implementation of these upgrades to meet a reporting deadline can have serious patient safety risks and is a major expense and burden, particularly to small practices,” Lopez said in a statement.nn
CMS also added an additional low-volume threshold exemption to MIPS for next year. To be excluded, providers or groups need to meet at least one of the following conditions:nn• Have $90,000 or less in Medicare Part B allowed charges for covered professional services.n• Provide care to 200 or fewer Part B-enrolled patients.n• Provide 200 or fewer covered professional services under the PFS.nnThe minimum period for each performance category remains unchanged, so quality and cost stay at 12 months while improvement activities and promoting interoperability remain at a continuous 90-day period.nnHowever, the weighting to the final score of the cost and quality categories have both changed. Cost increases from 10 percent to 15 percent of the total score, and quality drops from 50 percent to 45 percent.nnOriginal 
If you have been following our recent series of how to improve your bottom line, hopefully you have read some valuable information that you found insightful for your practice. Whether you have looked at your finances personally or not, Welter Healthcare Partners is available to help! We want you to be profitable, just as much as you do!nnFor over 20 years, Welter Healthcare Partners has helped physicians and practices increase revenue and thrive! We understand that proper revenue cycle management is the Lifeline of your practice! We have successfully helped thousands of practices increase revenue by 10 – 20%!nnDue to the unprecedented challenges you face, we will perform… nA FREE REVENUE ASSESSMENT AND FREE FOLLOW UP CONSULTATION WITH NO OBLIGATIONnnAllow us to quickly, professionally and confidentially assess your practices’ revenue cycle. There is absolutely no obligation! If we can help you we will Let you know how, and why. If we can’t help, we will be straight-up and tell you. You have nothing to lose, and possibly a lot more reimbursement to gain!n