Message From Your Region 8 Representatives | October 2018
Dear Region 8 West,
Now is a good time to hold a compliance meeting in order to prepare for CMS’s final rule regarding the 2019 Medicare Fee Schedule.
We should hear the results within the first week of November. By meeting now, you and your staff can brace for any potential changes. Should any of the CMS proposals be made final, you may need to work fast to prepare for January 1st
At this point, no indications have been given as to whether CMS will retain proposals from last June, which include a list of changes to payment and documentation requirements. One proposal, collapsing Level 2 through Level 5 Evaluation and Management (E/M) codes into one payment, roughly equates to a Level 3.6 payment. Proposals also include institution of a Multiple Procedure Payment Reduction (MPPR) which will reduce payment if an E/M and procedure are performed on the same date of service. Letters from medical societies have suggested delaying all of the proposals so new concepts can be analyzed for impact and best assimilated into our healthcare system.
Consider the impact of a collapse of Level 2 through Level 5 E/M codes for new and established patients. How will you alter provider education continue to accommodate the new changes? How should educators respond to providers who claim that there is no need to document beyond the Level 2 requirements? Change in documentation standards will have an impact on risk adjustment and Hierarchical Condition Category (HCC) code capture. How do we best promote the capture of information in light of potential policies that make History and Examination documentation optional?
A discussion at a compliance meeting would permit discussion about these areas. Many providers are not aware of significant documentation and coding changes and may feel blindsided if they are not given advance warning.
In addition to collapsing Level 2 through 5 E/M codes, also consider how your work environment would react to the Multiple Procedure Payment Reduction. Will your providers choose to change their practice patterns is they are financially penalized for performing an E/M and procedure on the same date of service? Will providers recommend patients return a separate day in order to circumvent MPPR? Or, will the providers refer the patient to another provider for the service? Or, will the provider continue working the same as now and accept the payment reduction?
Changes within CMS’s 2019 proposal have far reaching effects. Imagine a provider who is reimbursed based on RVU. Will contracts need to be modified? How will productivity, especially in a new era that increasingly embraces value of volume, be calculated if new proposals are made permanent?
For now, it is worth bracing for potential change. As an AAPC member, you will benefit from new articles posted on the AAPC Knowledge Center. Articles, written by AAPC editors and guest authors (possibly you!) will give us breaking news. To engage with a discussion, we encourage you to comment on the articles. The author will reply and we hope to engage in the conversation by posting comments too.
CMS wants documentation, coding and billing to be less burdensome for providers. They want providers to focus on the patient while the health record captures pertinent information. As an AAPC member, you are in a perfect position to understand the new CMS proposals and serve as a knowledgeable resource for your medical team.
Good luck with your compliance meetings and we will be watching the Knowledge Center!
Michael Warner, DO, CPC, CPCO, CPMA, AAPC Fellow
Mary Wood, CPC, CPC-I
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