CMS has finalized policy changes that streamline evaluation and management (E/M) payment and are aimed at reducing clinician burden.
CMS has finalized several documentation policies to provide immediate burden reduction for clinicians beginning on January 1, 2019, while other proposed changes to documentation, coding, and payment will not go into effect until 2021. Some of the changes going into effect in 2019 include eliminating the requirement to document the medical necessity of servicing care at a beneficiaries’ home rather than in office and removing the requirement to re-record data that has not changed since a patient’s prior visit as long as the clinician indicates in the chart that the information was reviewed and verified. Beginning in 2021, CMS will pay a single rate for E/M office/outpatient visit levels 2 through 4 for established and new patients while maintaining the payment rate for E/M office/outpatient visit level 5. For E/M office/outpatient levels 2 through 5 visits, CMS will allow for flexibility in how visit levels are documented— specifically a choice to use the current framework, medical decision making, or time. CMS also finalized the adoption of a new “extended visit” add-on code for use only with E/M office/outpatient level 2 through 4 visits to account for the additional resources required when practitioners need to spend extended time with the patient.
CMS will begin reimbursing clinicians for communication technology-based services.
CMS has finalized the proposal to pay for two newly defined physician’s services utilizing communication technology. These two services are the brief communication technology based service, or virtual check in (HCPCS code G2012), and the remote evaluation of recorded video and/or images submitted (HCPCS code G2010). These services will allow practitioners to decide whether an office visit or other medical service is needed, improving efficiency and convenience for both the practitioner and beneficiary.
The list of Medicare reimbursable telehealth services is expanding.
The 2019 Physician Fee Schedule Final rule expands telehealth services in two areas. One expansion is the addition of HCPCS codes G0513 and G0514 (Prolonged preventive service(s)) to the list of approved telehealth services. Additionally, CMS is implementing a provision from the Substance Use-Disorder Prevention that Promotes Opioid Recovery and Treatment (SUPPORT) for Patients and Communities Act that removes the originating site geographic requirements and adds the home of an individual as a permissible originating site for telehealth services furnished for purposes of treatment of a substance use disorder or a co-occurring mental health disorder for services furnished on or after July 1, 2019. Previously patients suffering from substance use disorder or a co-occurring mental disorder, were required to seek treatment at a qualifying treatment center.
Starting in 2019, MIPS eligibility has been expanded to include non-physician healthcare providers.
Physical therapists, occupational therapists, speech language pathologists, audiologists, clinical psychologists, registered dietitians, and nutrition professionals are now included in the definition of MIPS eligible clinicians. Non-physician healthcare providers are encouraged to check their participation eligibility at qpp.cms.gov and to begin learning about the performance year 2019 MIPS requirements associated with each MIPS performance category: Quality, Promoting Interoperability, Cost, and Improvement Activities.
Some eligible clinicians who are exempt from MIPS can opt-in and potentially earn a positive payment adjustment.
Clinicians may now choose to opt-in to MIPS if they meet or exceed at least one, but not all of the low volume threshold criteria. The low-volume threshold criteria includes, (1) billing less than, or equal to $90,000 in Part B allowable charges for covered professional service, (2) providing care to less than, or equal to 200 Part B enrolled beneficiaries, or (3) providing less than, or equal to 200 covered professional services under the Physician Fee Schedule. The ability to opt-in to the MIPS program grants clinicians and providers the opportunity to earn a positive payback adjustment, without first satisfying the previously needed requirements for participation. More providers will be eligible, creating a greater pool for sharing of data and information that will work to better the healthcare experience.
During the transition to implement the policy changes outlined in the 2019 Physician Fee Schedule, Veradigm will be there to help you navigate every step forward. For more details on any of the provisions discussed above, please see review the CMS 2019 Physician Fee Schedule Final Rule Fact Sheet.