"A nickel ain't worth a dime anymore."
-- Yogi Berra
On July 12, CMS released the 2019 Revisions to Payment Policies Under the Physician Fee Schedule and Other Revisions to Medicare Part B proposed rule. The proposal also includes several changes to the Quality Payment Program (QPP) -- revisions that CMS used to publish separately from the fee schedule.
This post focuses on the Medicare physician fee schedule portions of the proposed rule. In my Aug. 14 post, I will cover the proposed changes to QPP and provide additional perspective on changes to the Medicare fee schedule.
Building on its Patients Over Paperwork initiative, CMS has proposed several changes in policy and practice aimed at reducing the administrative burden of physicians participating in the Medicare program. The most notable is a dramatic reduction in documentation requirements for evaluation and management services. CMS has proposed that documentation for history and exam should focus on interval history since the patient's previous visit. In addition, the agency has proposed that physicians be allowed to document based on the 1995 or 1997 documentation guidelines, their level of medical decision-making, or time spent.
CMS also has proposed that physicians be allowed to review and verify certain information in the medical record that has been entered by ancillary staff or the beneficiary, rather than requiring them to re-enter the information themselves. The AAFP suggested this change to CMS, and we are pleased to see the agency embrace it.
The most intriguing -- and controversial -- portion of the proposed rule would collapse the number of codes for office visits by new patients (99201-99205) and existing patients (99211-99215) from five levels in each category to just two per category. In addition, CMS proposed adding a new code that would provide a $5 bump-up to the revised existing patient code for primary care, bringing the total for that code to $98. Figure 1 below shows the current value of each code and the proposed value of the collapsed codes. I provide some analysis and perspective in the Wonk Hard section below.
CMS estimates that the 2019 physician fee schedule conversion factor will be $36.0463, a slight increase from the 2018 conversion factor of $35.9996.
In addition to the changes outlined above, CMS proposes
The release of the 2019 Medicare physician fee schedule and QPP proposed rule has caused quite a stir in the physician community during the past few days. As is the case with all major policy proposals, there is much information to unpack and evaluate. The AAFP avoids snap judgments based on cursory reads of summaries and instead focuses on digging into the proposal and evaluating its positive and negative impacts on family medicine.
Although AAFP staff members are still evaluating the impact of the proposed rule on family physicians and the Medicare beneficiaries they care for, I want to provide some initial high-level takeaways:
Stephanie Quinn, AAFP Senior Vice President of Advocacy, Practice Advancement and Policy. Read author bio »