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NEWS FLASH: CMS Changes to E/M for 2019 and Beyond
February 2019

The existing 1995 and 1997 Evaluation and Management (E/M) documentation guidelines are still in place for 2019 and 2020, despite some updates and clarifications, and it is highly recommended that practices continue to monitor their E/M coding and documentation on a regular basis - we can be assured that payers are!

The Final Rule for physician services for 2019 includes the following two items related to office/outpatient E/M services:

  • For both new and established patients, CMS has clarified that providers do not need to re-record the chief complaint and/or history elements that are obtained by ancillary staff as long as the provider reviews the information and documents having done so. That particular point has always been part of the official guidelines, but with wording that was sometimes open to interpretation.

  • For established patients only, the Final Rule also states that when there is relevant history or exam information already contained in the medical record, providers do not need to re-record the defined list of required elements as long as they review and update as needed and there is evidence they have done so – and instead, can focus on what has changed.

CMS has emphasized that both of the above changes are optional and, as this article is being written, the official guidelines have not yet been revised to reflect the new information. It is also unclear at this point which, if any, commercial payers will follow suit. Thus it is probably best not to make major changes to your coding and documentation practices until more is known.

Looking to the future, CMS is also moving forward (finally!) with more significant changes to the E/M guidelines that were finalized in this year’s Final Rule, but will not be implemented until calendar year 2021. Their stated goal is to have the guidelines better reflect current medical practice. The changes will include reduction in payments via the establishment of a single rate for E/M levels 2-4, along with reduced documentation requirements. There will be also be multiple options related to E/M reporting, but we are not getting into the details here because CMS (and potentially commercial payers as well) will most likely come out with numerous revisions and/or clarifications over the next two years – as usual, we should all “Stay tuned!”

For more information on how FHC can help with your E/M coding and documentation reviews, please contact Charla Mailey at (612) 752-2607.



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