Physician group: Yes, revise E/M guidelines, please

You'll find the American College of Physicians (ACP) in full support of significantly overhauling the documentation guidelines for E/M services, an initiative that CMS said it would be undertaking in the near future.

 

In a letter in response to the 2018 proposed Medicare physician fee schedule, ACP calls the current E/M documentation guidelines "outdated," noting that the guideilnes "specify that the required contents of the medical record in excruciating – and often irrelevant – detail."

 

As a reminder, the proposed fee schedule hardly minced words, either, calling the history and physical exam elements of both the 1995 and 1997 E/M guidelines "significantly outdated" and asking the medical community for feedback on the best approach to revamp them.

 

"The detailed guidelines often cause clinicians to over-document, creating 'note bloat' and making the medical record an ineffective source of communication," states the ACP letter.

 

To remedy the situation, ACP calls for the history and physical exam elements to be detached from auditing requirements, although they would still maintain an important role during a patient encounter. "Once these elements are no longer required for auditing purposes, the level of service should be determined by the complexity of the medical decision making for that encounter and allow physicians to focus on documenting what is necessary based on the unique needs of their individual patients," states ACP.

 

Care management services also fall under the scope of ACP's feedback. Specifically, the group would like CMS to further reduce the documentation burden associated with chronic care management (CCM) services (99490). Additionally, they would like to see synergy between care management and the annual wellness visit (AWV), calling for the AWV to be eligible as an official CCM care plan, which would streamline reporting.

 

ACP also seeks additional telehealth coverage and calls for another physician practice expense survey to better align payments. Read the ACP's full list of comments here: www.acponline.org/acp_policy/letters/comment_letter_to_cms_re_cy_2018_medicare_pfs_proposed_rule_2017.pdf.