CMS recently released proposed regulatory changes for 2019, including telehealth, MACRA, and pricing requirements. However, the most disruptive change is the “Patients over Paperwork” effort overhauling E&M documentation and coding rules in response to physician burnout blamed on the EHR and administrative tasks.
CMS is proposing a single billing level for New and Established Patients with modifiers to account for procedures, time, and complexity. Documentation requirements will be based on current level 2 E&M standards, with the expectation that providers focus documentation on change in history, medical complexity and time spent with the patient.
Drastically reducing documentation requirements should be a big win for providers, who on average are currently spending up to 40% of their day on documentation and other administrative tasks. CMS reports that the impact on provider revenue will be minimum at only a +/- 1-2%. My cynical side already assumes that means CMS plans to cut their total E&M payments by 2%. This is significant, and there will be winners and losers.
At first blush, providers with complex patients who average higher E&M codes will see the largest revenue fall. In theory, they can use the time, previously spent documenting, to see additional patients and make up revenue loss. However, very efficient physicians, those that have figured out how to efficiently practice and document, will also see a reduction in revenue as they won’t be the physicians who benefit from time-based coding.
There will be unintended consequences. EHR templates will require re-design, requiring extensive IT resources. Coding and compliance teams will need to re-tool their audit and education programs. Billed related edits and workqueues will require evaluation and modification, as will quality efforts based on codified data elements.
These are some of the potential impacts and questions which require further understanding.
Please join experienced healthcare CIO Wayne Thompson and myself for Fireside Chat on Thursday August 16 between 1-2pm ET, as we discuss the benefits and impacts this proposed change.