The 2019 Medicare Physician Fee Schedule (MPFS) proposed rule outlined three big changes that, if enacted, would effect documentation, coding, and payment for office/outpatient visit codes (99201-99215).
Proposal 1. Simplify History and Exam Documentation Requirements: Practitioners would be required to focus their documentation only on what has changed since the last visit or on pertinent items that have not changed, rather than re-documenting a defined list of required elements such as review of a specified number of systems and family/social history. Also, the practitioner could indicate in the medical record that they reviewed and verified the chief complaint and history, without having to re-enter the information.
Proposal 2: Remove History and Exam from E/M Leveling Decision: Under current E/M documentation guidelines, the history and exam are two of the three elements (along with MDM) to be considered when selecting the overall level of E/M service to be reported. CMS is proposing to eliminate the history and exam from consideration. As a result, MDM would stand as the sole determinant of E/M service level. Providers could continue to use time as the determining factor in selecting and E/M service level, if coordination and care comprise the majority of the visit.
Proposal 3: Pay a Single Rate for levels 2-5 E/M visits: In return for simplified documentation requirements and coding guidelines, CMS is proposing streamlined E/M payments. Providers would receive the same reimbursement ($135) for all level 2-5 new patient visits, and for all level 2-5 established patient visits ($93).
