Wednesday, 20 Mar 2019

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Proposed Changes for 2019 Medicare Fee Schedule

On July 12th the Centers for Medicare & Medicaid Services (CMS) released its proposed rule changes for the 2019 Medicare physician fee schedule.  This year, CMS has combined the Medicare physician fee schedule proposed rule with recommendations for the Quality Payment Program (QPP), which will be officially published in the Federal Register on July 27.

This 1,400-plus page proposal is being digested and commented by a wide variety of specialities and physician groups. CMS has issued a September 10th deadline for commentary. 

These changes aim to streamline clinician billing processes and expand patient access to high-quality health care. Notably they attempt to reduce documentation requirements towards more quality interactive time with patients.

The American College of Physicians ( has come out endorsing the proposed CMS changes stating:

  • "Documentation options: We strongly support the proposal to reduce the burden of current E/M documentation requirements, specifically by allowing E/M documentation to focus on medical decision making, as ACP has strongly advocated for in the past.
  • Add-on codes: ACP appreciates CMS’s proposal to help account for cognitive services provided by internal medicine physicians that are currently not adequately supported in the traditional E/M structure, through the use of a new add-on code for primary care visit complexity. This is in line with ACP’s longstanding recommendations to CMS. ACP will be examining whether the add-on payments, especially for services provided by primary care physicians, are sufficient given other changes proposed by CMS.
  • Redundancy in documentation: ACP is encouraged by the proposal to reduce documentation burdens on physicians by requiring them to only document changed information for established patients and to sign-off on basic information documented by practice staff. ACP strongly supports these changes, as they will reduce the documentation burden on clinicians, limit redundant information in the medical record, and cut down on duplicative time spent on re-documenting existing information.
  • New non-face-to-face services: CMS proposes to add new reimbursable codes for “virtual check-ins,” remote consults of patient videos and photos, and interprofessional online consultations."

The fee schedule recommendations include reducing documentation requirements for evaluation and management services and giving stronger support for telecommunications technology as a means of improving access to care.

CMS is breaking with the past by allowing more digital and remote care. CMS is seeking to pay separately for two newly defined physicians' services furnished using communication technology: brief communication technology-based service, or a virtual check-in, and a remote evaluation of recorded video and images submitted by patients.

Proposed changes to the QPP would reduce clinician burden, focus on outcomes and promote electronic health record interoperability.


The author has no conflicts of interest to disclose related to this subject

Rheumatologists' Comments

If the add-on code is not adequate than internist and rheumatologist will take big hits.

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