E/M Changes May Hit Podiatry and Teaching Attestation

E/M Changes May Hit Podiatry and Teaching Attestation

The Centers for Medicare & Medicaid Services (CMS) physician fee schedule proposed rule has some new Part B specific codes for Podiatry Evaluation and Management (E/M) services as well as some modification to Teaching Physician Attestation Rules for 2019.

Changes to E/M Service Codes

CMS has also proposed the addition of two podiatry E/M codes specific to Medicare Part B patients who are receiving podiatric care. The reason for these codes are also targeting the reduction of administrative burdens on podiatrists while enabling them to providing services to their patients. CMS modeled these codes after the ophthalmologic evaluation and management codes. These codes are:

GPD0X: Podiatry services, medical exam, and evaluation with initiation of diagnostic and treatment program, new patient. Work and Practice Expense RVUs are 2.72.

GDP1X: Podiatry services, medical exam, and evaluation with initiation of diagnostic and treatment program, established patient. Work and Practice Expense RVUs are 1.81.

GPD0X has a proposed reimbursement for 2019 of $97.89. And GPD1X has a proposed reimbursement for 2019 of $65.14. This is pretty good news since the current 2018 reimbursement for 99203 is $78.12 and 99213 is $52.20.

CMS has assigned a reference time of 28 minutes for new patient GPD0X with a threshold of 15 minutes and a reference time for established patient GPD1X of 22 minutes with a threshold time of 12 minutes.

Changes to Teaching Physician Attestation Documentation

The CMS 2019 proposed rule has made changes to the Teaching Physician Attestation documentation. The rule creates exceptions to the full Teaching Physician Attestation in order to reduce the administrative burden on teaching physcians.

However, keep in mind that the exception would not apply to services that fall under the following:

Evaluation and Management – CEMC

  • Hospital outpatient
  • Ambulatory settings
  • Renal dialysis services
  • Psychiatric services

The proposed change is significant. For services that do not take place in the above 4 settings, the Teaching Attestation may be documented by the physician, the resident or the nurse. The requirement to participate in the review and direct the service will be eliminated. The extent of the review and the direction that was provided should be part of the documentation per the proposed rule. I am sure that there are many teaching physicians who will welcome this change because many charts that I currently audit, that are missing the teaching physician attestation, usually have a resident statement about the teaching physician review.

 

Barbara Cobuzzi

Barbara Cobuzzi

Barbara J. Cobuzzi, MBA, CPC, CENTC, COC, CPC-P, CPC-I, CPCO, AAPC Fellow, is a consultant with CRN Healthcare Solutions in Tinton Falls, N.J. She is consulting editor for Otolaryngology Coding Alert and has spoken, taught, and consulted widely on coding, reimbursement, compliance, and healthcare-related topics nationally. Barbara also provides litigation support as an expert witness for providers and payers.Cobuzzi is a member of the Monmouth, N.J., AAPC local chapter.
Barbara Cobuzzi

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Barbara J. Cobuzzi, MBA, CPC, CENTC, COC, CPC-P, CPC-I, CPCO, AAPC Fellow, is a consultant with CRN Healthcare Solutions in Tinton Falls, N.J. She is consulting editor for Otolaryngology Coding Alert and has spoken, taught, and consulted widely on coding, reimbursement, compliance, and healthcare-related topics nationally. Barbara also provides litigation support as an expert witness for providers and payers. Cobuzzi is a member of the Monmouth, N.J., AAPC local chapter.

2 Responses to “E/M Changes May Hit Podiatry and Teaching Attestation”

  1. Sean Shanahan, DPM, MPH says:

    The proposed codes are improper and insulting as well as a disparity to podiatrist. They eliminate us from being identified as Physicians. Additionally, this is not a better reimbursement especially since when new patients (and even established patients) come to the office we don’t know what they have. It could range from gangrene, fractures, to a simple wart or diabetic foot care.
    each of these problems represents a different approach in may take more time than another problem. Additionally, it does not allow for modifier 25 or additional procedures to be bundled with this code.
    for example, a patient who is a diabetic comes in for a new visit and has a full evaluation perform and needs calluses trimmed. Under the new reimbursement, the podiatrist is only being paid one code, one price. The reimbursement is significantly less since we cannot bundle these codes. This is a way for CMS to eliminate Podiatry as a physician service. It is unfair and it eliminates equality amongst reimbursements. this will be hazardous to a patient’s Health as well as to the physician’s ability to maintain a healthy practice as expenses can not be properly met. The Snowball Effect that CMS is proposing will affect everybody but it will start with Podiatry.
    it is very evident that today our government is being run like a business where only the bottom line Mathers. When the bottom line matters, physicians and most importantly the patients will suffer.

  2. Barbara J. Cobuzzi says:

    Sean,

    Have you submitted your comments to CMS. The comment period ends on September 10th. It is important for you to give your feedback to CMS before that date.

    CMS will take comments on these proposed changes up to September 10, 2018. Submissions must be submitted in one of the following three ways:
    1. Submit electronic comments on this regulation to http://www.regulations.gov. Follow the “Submit a comment” instructions.

    2. Mail written comments to the following address ONLY: (Must be received by September 10th)
    Centers for Medicare & Medicaid Services
    Department of Health and Human Services
    Attention: CMS-1693-P
    P.O. Box 8016
    Baltimore, MD 21244-8016
    Please allow sufficient time for mailed comments to be received before the close of the comment period.

    3. By express or overnight mail, send written comments to the following address ONLY:
    Centers for Medicare & Medicaid Services
    Department of Health and Human Services
    Attention: CMS-1693-P
    Mail Stop C4-26-05
    7500 Security Boulevard
    Baltimore, MD 21244-1850

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