On July 12, 2018, the Centers for Medicare and Medicaid Services (CMS) released the proposed 2019 Medicare Physician Fee Schedule and MACRA Quality Payment Program (QPP) rule. This is the first year that CMS is combining the Medicare fee schedule and QPP rules.

There are a number of positive elements in the proposed rule. These include:

• New payments for physician services that are not part of a face to face office visit (virtual check-ins, remote consults of patient videos and photographs, and online consultations with other physicians)
• Continuation and expansion of the low volume threshold exception policy to exempt small practices from the Merit-based Incentive Payment System (MIPS) but only on a voluntary basis for those who want to participate.
• A reduction in problematic measures in the Promoting Interoperability provisions (formerly Meaningful Use and Advancing Care Information)
• A major reduction of the documentation burden for Evaluation & Management (E/M) office visit codes
• California Medical Association (CMA)-sponsored geographic payment updates for California physicians.

Proposed E/M Coding Changes

The CMS proposal to reduce the documentation burden for E/M codes would modify E/M services through collapsing codes and payment levels. The American Medical Association (AMA) looked at the specific impact on separately reported office visits and summarized the specific E/M impact by specialty. There is a net national reduction given the current distribution of E/M codes of close to 4 percent, with some specialties seeing reductions of up to 20 percent. The analysis does not include the new add-on codes because the data is not available.

CMA and AMA are working closely with all state and national specialty societies to determine the impact and where necessary, to develop joint alternative proposals. The physician community is working together to develop a consensus in our advocacy and communications with CMS, particularly to protect physicians treating complex patients.  This is an extremely complex rule with many moving parts and the best physician experts and advocates around the country are working on it together. 

CMA and AMA appreciate CMS’s genuine desire to reduce documentation burdens on physicians to allow them to focus on patients over paperwork. We have been in touch with CMS and the agency has indicated its willingness to work with the physician community on possible modifications to the proposal.

We will be focused on offering constructive recommendations that advance the twin goals of reducing administrative burdens and developing payment policies that enable physicians to deliver high quality care for seniors. 

For more information:

• AMA Summary of the Proposed Rule
• California Geographic Payment Impact Analysis
• Specialty Specific Impacts Including Payment Accuracy Adjustments
• Estimated Impact of CY2019 Evaluation and Management Proposed Policy by Medicare Specialty
• Estimated Impact on Total Allowed Charges by Specialty