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More Proof Your Voice Can Make a Big Difference: CMS Delays Problematic E/M Changes for 2 Years
Posted on: 11/19/2018

Last August, ISMS asked members for input on Medicare’s proposed changes to evaluation and management (E/M) documentation requirements and reimbursement.

Based on your responses, ISMS offered comments to the Centers for Medicare and Medicaid Services (CMS).

Good news! We got everything you wanted.

The Final 2019 Physician Fee Schedule and quality payment program (QPP) rule was released on November 1. CMS is implementing changes in 2019 that will ease documentation burdens and reduce the need to duplicative information. CMS is also postponing other changes that ISMS expressed strong concerns about, and will delay for two years the implementation of significant E/M coding changes that impact physicians’ payments.

Once again, your voice and your ISMS membership have had a direct impact on the lives of doctors and patients!

See an annotated version of the letter that ISMS sent to CMS on the members' behalf below.


Included in ISMS members' feedback was widespread agreement that the E/M documentation requirements were burdensome, confusing, and ultimately detrimental to a physician’s ability to provide efficient and high-quality patient care

While members were in favor of streamlining documentation requirements, they were deeply concerned about CMS’ proposal to collapse the E/M level payment rates. Members believed that, at a minimum, additional time and consideration would be needed to determine how E/M payment adjustments might affect patient access to care, particularly patients with complex medical needs.

ISMS urged CMS to finalize policies that would reduce the need for duplicative or irrelevant information when documenting an E/M service. Here are the specifics:

  • Allow physicians to focus documentation on patients’ history since their last visit, rather than re-documenting a complete medical history each time.
  • SUCCESS! CMS finalized beginning in 2019

  • Allow physicians to review and verify information in the medical record that has been documented by practice staff, rather than re-documenting the information.
  • SUCCESS! CMS finalized beginning in 2019

  • Remove the requirement that physicians document the need for a home visit rather than an office visit.
  • SUCCESS! CMS finalized beginning in 2019

ISMS believes that CMS’ intent to begin streamlining the E/M documentation process can be achieved immediately without rushing to restructure the entire coding framework. ISMS strongly opposed CMS’ proposal to collapse the current E/M coding levels and establish new, blended payment rates.

SUCCESS! CMS did not finalize this proposal for 2019. CMS will take more time to solicit additional stakeholder input and intends to implement changes to the E/M coding levels and payment rates in 2021.

ISMS is aware that the American Medical Association (AMA) has established a work group to analyze E/M coding issues, and we believe the AMA’s work will be useful in advancing meaningful discussions around improvements in the E/M coding framework.

SUCCESS! CMS specifically noted that delaying changes to the E/M coding and payment structure would provide the opportunity for CMS to respond to the work being done by the AMA and the CPT Editorial Panel, as well as other stakeholders. CMS will consider any changes that are made to CPT coding for E/M services, and recommendations regarding appropriate valuation of new or revised codes.

Finally, ISMS strongly opposed CMS’ proposal to introduce a multiple procedure payment adjustment for procedures that are performed in conjunction with E/M visits.

SUCCESS! CMS did not finalize this proposal

Questions? Contact ISMS' advocacy team at 800-782-4767 ext. 1470, or by email



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