DHPA joined the Patient-Centered Evaluation and Management Services Coalition in sending a letter to Centers for Medicare and Medicaid Services (CMS) and Congressional leadership supporting CMS’s proposed simplification of documentation requirements and opposing implementation of proposed payment changes in the Medicare Physician Fee Schedule Proposed Rule for Calendar Year 2019.
In the letters, the Coalition writes that it supports the goals of CMS’s “Patients Over Paperwork” initiative and appreciates Congress’s work to move our healthcare system to one that prioritizes patients and quality of care over volume and burdensome administrative requirements. The letters commend CMS for starting a serious discussion on simplifying documentation, coding and payment for patient office visits so that clinicians can keep their focus on providing the best possible care for Medicare beneficiaries.
However, the letters also state that additional modeling is needed to obtain more accurate estimates of the impacts of payment changes on medical practices and implications for patient care. Additionally, the Coalition requests that CMS finalize the sensible documentation reforms included in the Rule, while retaining the existing five-level coding structure. The letter request implementation of the following budget-neutral proposals:
- Allow physicians the option to document office visits based solely on the level of medical decision-making or the face-to-face time for the visit as an alternative to the current guidelines.
- Limit required documentation of an established patient’s history to the interval history since the patient’s previous visit for physicians who choose to continue using the current guidelines.
- Eliminate the requirement for physicians to re-document information included by practice staff or the patient in the medical record.
- Eliminate the prohibition on billing same-day visits by practitioners of the same group and specialty.
- Eliminate the requirement to document justification for a home visit instead of an office visit.
Click here to read the full letter to CMS.
Click here to read the full letter to Congressional leadership.