CMS Wants to Revise E/M Documentation Guidelines

CMS Wants to Revise E/M Documentation Guidelines

Among the many provisions detailed within the 2018 Physician Fee Schedule Proposed Rule, released July 13, the Centers for Medicare & Medicaid Services (CMS) acknowledges that the current evaluation and management documentation guidelines create an administrative burden and increased audit risk for providers:

Stakeholders have long maintained that both the 1995 and 1997 guidelines are administratively burdensome and outdated with respect to the practice of medicine, stating that they are too complex, ambiguous, and that they fail to distinguish meaningful differences among code levels. In general, we agree that there may be unnecessary burden with these guidelines and that they are potentially outdated, and believe this is especially true for the requirements for the history and the physical exam.

In response, CMS announced its intention to undertake a multi-year effort—with the input of providers and other stakeholders—to revise the current E/M documentation guidelines. This revision will likely include removal of the history and exam documentation requirements:

Evaluation and Management – CEMC

We are … specifically seeking comment on whether it would be appropriate to remove our documentation requirements for the history and physical exam for all E/M visits at all levels.
We believe medical decision-making and time are the more significant factors in distinguishing visit levels, and that the need for extended histories and exams is being replaced by population-based screening and intervention, at least for some specialties.… As long as a history and physical exam are documented and generally consistent with complexity of MDM, there may no longer be a need for us to maintain such detailed specifications for what must be performed and documented for the history and physical exam (for example, which and how many body systems are involved).

The full comments can be found beginning on page 374 of the Proposed Rule, as provided in the hyperlink, above. More details are sure to follow.

Comments on the CMS proposal to revise the E/M documentation guidelines are due no later than Sept. 11, and can be submitted by one of four methods:

1. Submit electronic comments on this regulation to www.regulations.gov. Follow the instructions for “submitting a comment.”

2. Mail written comments to:
CMS-1676-P 2
Centers for Medicare & Medicaid Services, Department of Health and Human Services, Attention: CMS-1676-P
P.O. Box 8016
Baltimore, MD 21244-8013.
Allow sufficient time for mailed comments to be received before the close of the comment period.

3. By express or overnight mail. You may send written comments to:
Centers for Medicare & Medicaid Services, Department of Health and Human Services, Attention: CMS-1676-P
Mail Stop C4-26-05
7500 Security Boulevard
Baltimore, MD 21244-1850.

4. Deliver (by hand or courier) written comments before the close of the comment period to:
Centers for Medicare & Medicaid Services, Department of Health and Human Services,
Room 445-G, Hubert H. Humphrey Building,
200 Independence Avenue, SW., Washington, DC 20201

When commenting, refer to file code CMS-1676-P.

John Verhovshek

John Verhovshek

John Verhovshek, MA, CPC, is Managing Editor at AAPC. He has covered medical coding and billing, healthcare policy, and the business of medicine since 1999. He is an alumnus of York College of Pennsylvania and Clemson University, and a member of the Asheville-Hendersonville AAPC Local Chapter.
John Verhovshek

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John Verhovshek, MA, CPC, is Managing Editor at AAPC. He has covered medical coding and billing, healthcare policy, and the business of medicine since 1999. He is an alumnus of York College of Pennsylvania and Clemson University, and a member of the Asheville-Hendersonville AAPC Local Chapter.

2 Responses to “CMS Wants to Revise E/M Documentation Guidelines”

  1. sharlia says:

    that is very true and with that being said i have a question for an e/m code for cigna insurance is it ok to code a 99243 with a 92567?

  2. Brad Ericson says:

    Hi Sharlia,

    I bet someone out on the Member Forum might have an answer to your question.

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