Excellent article by Healthcare Compliance Pros (http://www.healthcarecompliancepros.com):
On July 12th, the Centers for Medicare & Medicaid Services (CMS), released the Proposed Rule and made it available for comment. There was a lot of discussion about Evaluation and Management (E/M) coding and CMS teased changes for improvements to “the nation’s healthcare system and a way to restore the doctor-patient relationship by empowering clinicians to use their electronic health records (EHRs) to document clinically meaningful information.”
On November 1st, 2018, CMS issued a final rule that includes updates or “changes” to payment policies, payment rates, and quality provisions for services furnished under the Medicare Physician Fee Schedule (PFS) on or after January 1, 2019.
E/M changes to expect in 2019 and 2020
According to CMS, for calendar years 2019 and 2020, several documentation policies will be implemented that is said to provide immediate burden reduction. During these years, CMS will continue the current coding and payment structure for E/M office/outpatient visits and practitioners should continue to use either the 1995 or 1997 E/M documentation guidelines to document E/M office/outpatient visits billed to Medicare. The following policies are being finalized;
•Elimination of the requirement to document the medical necessity of a home visit in lieu of an office visit;
•For established patient office/outpatient visits, when relevant information is already contained in the medical record, practitioners may choose to focus their documentation on what has changed since the last visit, or on pertinent items that have not changed, and need not re-record the defined list of required elements if there is evidence that the practitioner reviewed the previous information and updated it as needed. Practitioners should still review prior data, update as necessary, and indicate in the medical record that they have done so;
•Additionally, for E/M office/outpatient visits, and for new and established patients for visits, practitioners need not re-enter in the medical record information on the patient’s chief complaint and history that has already been entered by ancillary staff or the beneficiary. The practitioner may simply indicate in the medical record that he or she reviewed and verified this information; and
•Removal of potentially duplicative requirements for notations in medical records that may have previously been included in the medical records by residents or other members of the medical team for E/M visits furnished by teaching physicians.
Our Recommendations
Initially, from these proposed changes, many healthcare professionals thought that auditing may not be as necessary as it was before. This is NOT the case. In fact, auditing is more important than ever before! With this in mind, HCP recommends baseline audits for at least 25 encounters per provider and subsequent audits based on results of baseline audits. Now is a good time to perform a baseline audit, to ensure accurate coding and documentation practices are in place before CMS policies are further updated for 2021 and beyond. For the calendar year 2021, CMS intends to finalize several other E/M policies with feedback from the public to “potentially further refine the policies.” HCP will be providing a breakdown of CMS’ current plans and what we expect will really happen to CMS’ 2021 E/M policies.
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