Following an announcement last year by the Centers for Medicare and Medicaid Services (CMS) about its plan to collapse evaluation and management (E/M) code and payment levels, the American Medical Association (AMA) CPT Editorial Panel and the AMA/Specialty Society RVS Update Committee convened a workgroup to develop an alternate solution.

In June of this year, the AMA workgroup released its new guidelines, which align E/M office visits with two elements – time or medical decision-making – for reporting purposes.  The CPT coding changes will retain five levels of coding for established patients, reduce the number of levels to four for new patients and revise the code definitions. A new CPT code for extended office visit time will also be implemented.

When CMS released its draft 2019 Medicare Physician Fee Schedule and MACRA Quality Payment Program rule earlier this summer, the agency had largely accepted AMA’s recommended changes. However, some aspects of the CMS proposal depart from these recommendations and would exacerbate the negative payment impacts from this policy change on physicians in certain specialties. Although the surgical specialties were incorporated into AMA’s guidelines, the CMS proposal would not apply the office visit increases to the global surgery packages.

The California Medical Association (CMA) strongly opposes CMS’ proposal to not incorporate the adjusted values for the revised E/M codes into the 10- and 90-day global surgical codes. Only updating the values for stand-alone E/M visits, but not for the global surgical package will disrupt the relativity between procedures across the entire Medicare fee schedule and create inappropriate specialty differentials in payment for physicians providing the same service. 

CMA recently submitted comments to CMS on this issue, urging the agency to adopt the CPT codes, CPT guidelines and recommendations exactly as recommended by the AMA CPT Editorial Panel. The final rule should be published in November 2019 but the E/M coding changes will not be effective until Jan 1, 2021.

CMA is also urging CMS to adopt a positive payment update to offset the “budget neutral” impact of long over-due payment increases to office visits.