CMS modifies proposed changes to E/M codes, delays implementation until 2021

Doctors spoke, and CMS listened—delaying any changes to codes for Medicare patient visits until 2021.

While the Centers for Medicare & Medicaid Services moved ahead with parts of its plan to consolidate codes for Medicare patient visits, it made changes in response to the thousands of comments it received from doctors who worried that the plan would cut revenues for physicians who care for Medicare patients with complicated health conditions.

In a conference call today, CMS Administrator Seema Verma said the agency will consolidate codes for “evaluation and management” (E/M) visits to three—maintaining the level 5 code that is used for physicians who see the sickest patients who require more services.

The agency will also delay implementation until 2021 so it can continue to work with doctors to iron out details.

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“We know this is going to have a tremendous impact on many physicians in America. We want to get it right,” Verma said.

But she said doctors should not think that the two-year implementation means CMS will not enact the change. “I think this hasn’t been updated in 20 years,” she said about the coding requirements for physician services provided in office visits.

The E/M code changes are part of a final rule (PDF) that outlines the physician fee schedule for 2019 along with changes to the third year of the physician payment system implemented under MACRA.  

RELATED: Good or bad idea? Some worry that E/M coding update could underpay doctors with sickest patients

The American Medical Association, the country’s largest physician organization, said it applauded the government for revising its original proposed E/M policies.

“The AMA also is grateful that the administration is not moving forward in 2019 with the payment collapse of E/M codes,” said AMA President Barbara L. McAneny, M.D. The two-year window for implementation of the proposal will allow time for an AMA-convened workgroup to make recommendations on the complicated topic, she said.

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The Medical Group Management Association also said it welcomed CMS’ decision to revise the codes and defer action to 2021. “But there’s more work to be done,” said Anders Gilberg, senior vice president of government affairs. "Blending payments rates in 2021 won't necessarily reduce burden, especially with CMS’ newly required add-on codes.”

CMS will immediately finalize several burden-reduction proposals that doctors supported, effective Jan. 1, 2019. But in response to concerns, the final rule includes revisions that preserve access to care for complex patients, equalize certain payments for primary and specialty care and allow the delay in implementation of E/M coding reforms until 2021.

CMS backed off on immediate implementation after it received over 15,000 comments on a proposed rule released in July—many of them in opposition to the change, which would have collapsed payment rates for eight office visit services for new and established patients down to two each.  

Saying it could underpay doctors who treat the sickest patients, more than 150 medical groups also sent a letter opposing the plan to consolidate E/M codes.

Changes to the E/M codes were the most controversial issue but not the only change made by CMS. CMS released a fact sheet with more details about the physician fee schedule. The agency also released a fact sheet (PDF) outlining changes to its quality payment program under MACRA and an executive summary (PDF) with further details.