The ACC joined the America Medical Association (AMA) and more than 165 stakeholder organizations in submitting a sign-on letter that praises the Centers for Medicare and Medicaid Services (CMS) for its efforts to alleviate excessive evaluation and management (E/M) documentation requirements, but calls on the agency to reevaluate select policy changes related to the collapse of payment rates included within in the recently released 2019 Medicare Physician Fee Schedule proposed rule. The College will submit additional comments directly to CMS by Sept. 10. Members can submit individual comments here.

The organizations strongly support CMS' goal of reducing administrative burdens associated with documentation and urge for the immediate adoption of several proposed policy changes to alleviate this problem, 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.

While the letter applauds the agency's "Patients Over Paperwork" initiative, the aforementioned organizations warn CMS of potential unintended consequences that could result from policies in the proposed rule that would collapse payment rates for eight office visit services for new and established patients down to two each.

"We oppose the implementation of this proposal because it could hurt physicians and other health care professionals in specialties that treat the sickest patients, as well as those who provide comprehensive primary care, ultimately jeopardizing patients' access to care," the letter states. The letter also opposes the adoption of the proposed multiple service payment reduction policy, as the issue of multiple services on the same day of service was factored into prior valuations of the affected codes.

The medical community wants to help CMS work through the complicated issues surrounding the appropriate coding, payment and documentation requirements for different levels of E/M services. Toward that end, the ACC and fellow stakeholders strongly support AMA's creation of a workgroup of health care professionals with deep expertise in defining and valuing codes. This workgroup is already analyzing E/M documentation and coding issues to provide CMS with concrete solutions for implementation as soon as the 2020 Medicare Physician Fee Schedule.

The letter concludes by encouraging the administration to adopt certain documentation changes on Jan. 1, 2019, and to fully embrace the assistance of the collaborative workgroup to identify mutually agreeable policies that will achieve the shared goal of simplifying E/M documentation burdens while mitigating any unintended consequences. Read the full letter here.

CMS will post its decisions in the final rule by Nov. 2. ACC Advocacy staff will continue to communicate developments on this issue as they become available.

Keywords: ACC Advocacy, Centers for Medicare and Medicaid Services, U.S., House Calls, Medicaid, Medicare, Fee Schedules, Documentation, Office Visits, Primary Health Care

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