In the days after CMS
dropped a bombshell of a proposed fee schedule, experts and industry groups continue to make sense of the expected aftermath. No proposals are final, of course, but the ideas floated -- around E/M payments and documentation, in particular -- could prove significantly disruptive to physician practices around the country.
Part of CMS' proposed plan, which could take effect as early as Jan. 1, 2019, is to create a single payment rate for medium- to high-level E/M codes for both new and established patients. For instance, CMS wants to pay providers the same fee (about $93) for codes 99212-99215, which traditionally have been paid at distinct rates based on the complexity of patient care. The federal agency also seeks to broaden E/M documentation options, allowing practices to self-select from a patchwork of options, including the current guidelines or a single element, such as medical decision-making or time.
The rule's fine print left some experts flabbergasted. "This is insanity for CMS," exclaimed Terry Fletcher, CPC, president of Terry Fletcher Consulting in Laguna Beach, Calif. "Are they crazy?"
Some specialty groups also took exception to the E/M provisions. Ted Okon, executive director of the Community Oncology Alliance,
called the proposals "puzzling" and said that CMS' "scheme to pay a physician the same amount for evaluating a case of sniffles and a complex brain cancer simply defies all logic."
Others see CMS moving in the right direction. The American College of Physicians (ACP), representing some 180,000 internal medicine providers, announced that it
was generally "optimistic" about the rule, expressing support for documentation-reduction initiatives, new add-on codes and telehealth expansion. The physician group also said it is "encouraged that CMS is exploring alternatives to the current E/M payment structure," but the proposals "require greater examination to ensure that they do not disadvantage physicians who care for complex and frail patients."
“Reimbursing the most complex E/M services to such patients at the same flat level as healthier patients with less complex problems could undervalue the physician skills and training needed to care for such patients," said Ana María López, M.D., ACP president.
Given the dizzying proposals, CMS is likely to receive a significant amount of comments by the Sept. 11 submission deadline as trade groups, practitioners, consultants and other stakeholders unpackage the various provisions. Chances are, the rule will not pass as proposed, experts says.
"I don’t believe this will be approved in its current format," Fletcher says. "There will be changes because there will be too many physicians and societies that will disagree with the current proposed rule."
But CMS' opening salvo may drive the conversation forward for months, or years, to come. "I have a feeling that we will be addressing this for some time," says Valerie Rock, CPC, senior manager with consultancy PYA in Atlanta.