Practice Management

CMS Seeks Input on Revised E/M Fees

Changes are scheduled to take effect in 2021

Physician reads laptop screen and takes notes

After proposed changes to Medicare’s evaluation and management (E/M) fee structure generated controversy in 2018, the federal government decided to delay implementation until 2021, allowing time to field suggestions from physician groups on how to proceed.

The Centers for Medicare & Medicaid Services (CMS) had intended for the revisions to lighten the heavy paperwork burden associated with E/M codes, a persistent complaint among physicians. But when the new fees were evaluated, the potential for revenue shortfalls overshadowed concerns about cutting red tape.

The original proposal called for E/M fees between levels 2 and 5 to be “blended” into a single payment, a figure close to an average of those four levels. Thus, the existing fee structure for new patients (level 2: $76; level 3: $110; level 4: $167; level 5: $211) would be blended into a single flat fee of $135, for example. This is beneficial for practices with healthy patient populations but could hurt those with less healthy patients.

“There are a lot of factors involved,” says Mollie Gelburd, JD, an associate director of government affairs at Medical Group Management Association, a trade group for practice managers. “And applying this sort of one-size-fits-all [approach] doesn’t really take into account all those factors.”

Office E/M visits account for approximately 20% of all Physician Fee Schedule charges, according to Gelburd, so revenue could be affected. After the revisions were proposed last summer, reactions were almost universally negative. A letter petitioning CMS to reconsider the changes was signed by 170 physician professional organizations.

As a compromise, the agency offered to confine blended payments to levels 2 through 4. Although this version was finalized and is scheduled to go into effect on January 1, 2021, regulators have made it clear they are willing to make changes prior to that date based on physician input.

“Informally, CMS has said it wants to see consensus from provider groups and stakeholders,” notes Gelburd. “They don’t want to go through a period where everyone has different recommendations on fixing this problem.”

Although the revised fee structure was delayed, other paperwork-reducing changes did go into effect this year, such as eliminating re-documentation requirements and allowing more staff record keeping. However, Gelburd says, these changes have had minimal impact; she hopes whatever conclusion CMS ultimately reaches will target the burden more aggressively. “E/M documentation burden is a huge issue,” she says. “It’s something we hear about all the time.”


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