CMS Physician Final Fee Schedule for 2019

There seems to be a lot of confusion that the E/M codes and levels are changing in 2019. This is NOT accurate. The changes to the levels of E/M’s and reimbursement will not occur until 2021.

Here is what is happening in 2019. Everything is spelled out in this link.

The four bullet points below for 2019 and 2020 really do not reflect anything different from what is already required and has always been required, except for the first bullet. (See highlights below.)

For CY 2019 and CY 2020, CMS will continue the current coding and payment structure for E/M office/outpatient visits and practitioners should continue to use either the 1995 or 1997 E/M documentation guidelines to document E/M office/outpatient visits billed to Medicare. For CY 2019 and beyond, CMS is finalizing the following policies:

  • Elimination of the requirement to document the medical necessity of a home visit in lieu of an office visit;
  • For established patient office/outpatient visits, when relevant information is already contained in the medical record, practitioners may choose to focus their documentation on what has changed since the last visit, or on pertinent items that have not changed, and need not re-record the defined list of required elements if there is evidence that the practitioner reviewed the previous information and updated it as needed. Practitioners should still review prior data, update as necessary, and indicate in the medical record that they have done so; italics and underline is for emphasis
  • Additionally, we are clarifying that for E/M office/outpatient visits, for new and established patients for visits, practitioners need not re-enter in the medical record information on the patient’s chief complaint and history that has already been entered by ancillary staff or the beneficiary. The practitioner may simply indicate in the medical record that he or she reviewed and verified this information; and Again, has always been required
  • Removal of potentially duplicative requirements for notations in medical records that may have previously been included in the medical records by residents or other members of the medical team for E/M visits furnished by teaching physicians. This might provide a little relief.
  • The -25-modifier reduction when applied to an E/M on the same date as a minor procedure, did NOT pass. This discussion is tabled for further review into 2020.
  • Communication based services for 2019 – Codes 99446-99452 will be available for a physician and/or NPP to bill in the final 2019 Medicare physician fee schedule and are not subject to the same rules or restrictions as Medicare telehealth services. There is no originating site or geographical area qualification to be eligible for services. However, there are many hurdles to consider before submitting these codes for payment.

Enroll in my 2019 CPT update for details.