“Bureaucracy is the only constant in the universe.” Dr. McCoy, Star Trek IV The Voyage Home.
CMS received many comments | Guidelines for E/M
CMS received many comments but not consensus about how to revise the Evaluation and Management (E/M) guidelines.
You may remember that in the proposed physician fee schedule rule, CMS asked for comments about the E/M guidelines. I wrote about their request for comments.
CMS noted that they hear from stakeholders that the guidelines are overly burdensome and outdated.
Physicians complain that with the advent of electronic health records, guidelines written in 1995 and 1997 do not adequately reflect the work done. Although there are relatively few E/M audits, medical practices find the requirements burdensome.
So, CMS asked for comments.
The final rule released at the beginning of November describes the comments that CMS received.
There were varying opinions about the importance of history and exam, with some commenters saying that history and exam are critically important in all notes, and others saying that the level of history and exam requirements for high-level visits is not always clinically relevant.
Some commenters believe that the E/M code set itself should be changed, not just the documentation guidelines for these codes. Some commenters urged CMS to implement changes over multiple years with a task force, public forums and listening sessions. CMS noted that opinions varied by specialty.
Nothing is changing in the near future.
How far into the horizon before there will be changes? That is hard to know. This is how CMS ended this section fee schedule.
“We expect to continue to work on all of these issues with stakeholders in future years though we are immediately focused on revision of the current E/M guidelines in order to reduce unnecessary administrative burden.”
I suspect that the next thing we will hear will be in the 2019 proposed rule, released in the summer of 2018.
This final rule did not describe what the next steps in the process will be or who will be involved. I think it is a safe bet that the AMA will be at the table.
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