On Nov. 1, 2018, the Centers for Medicare and Medicaid Services (CMS) released the final 2019 Physician Fee Schedule, with many positive improvements over the proposed rule.

CMS has postponed for at least two years its proposal to collapse evaluation and management (E/M) code and payment levels. The California Medical Association (CMA) and the American Medical Association (AMA) advocated against this proposal, as it would have substantially cut payments, with potential unintended consequences for physicians in specialties that treat the sickest patients, as well as those who provide comprehensive primary care – ultimately jeopardizing patients’ access to care.

CMS also dropped its proposed multiple service payment reduction policy. CMA and AMA had pushed back on this proposal, as the issue of multiple services on the same day of service was factored into prior valuations of the affected codes.

The final rule also includes a number of documentation changes intended to reduce the administrative burdens on physicians to allow them to focus on patients over paperwork, including:

• Changing the required documentation of the patient’s history to focus only on the interval history since the previous visit;
• Eliminating the requirement for physicians to re-document information that has already been documented in the patient’s record by practice staff or by the patient; and
• Removing the need to justify providing a home visit instead of an office visit.

Implementation of these policies will streamline documentation requirements, reduce note bloat, improve workflow, and contribute to a better environment for physicians and their Medicare patients.

Other positive elements of the final physician payment rule include:

• CMA-sponsored California geographic payment increases.

• New payments for physician services that are not part of 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)

For more information, see the AMA summary of the final rule and the CMS fact sheet on the PFS changes for 2019.