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CMS Modifies and Finalizes E&M Payment Changes: Potential Implications for Hospice and Palliative Care

Posted on Friday, December 21, 2018 12:35 AM

CMS proposed that beginning in January 2019 documentation requirements for E&M visits from levels 2 through 5 would be limited to existing requirements for a level 2 visit, but to also compress payments such that a single rate would be paid regardless of whether a practitioner provided a level 2, 3, 4 or 5 visit. These changes met with strong opposition from the physician community.  In response, the physician payment regulations CMS issued in late November finalized a plan to collapse E&M payment rates for office and outpatients visits in levels 2 through 4 to a single rate (rather than 2 through 5, as proposed), retaining a separate payment rate for level 5 office and outpatient visits to “better account for the care and needs of complex patients.”  Additionally, these changes would not be applicable until CY2021.  As proposed, the modifications will also be accompanied by a new “extended visit” add-on code as well as add-on codes for primary care visits and certain specialized medical care.  The reduced documentation requirements would accompany these changes.

While it is believed that most of the physician services billed by hospices and physician practice-based palliative care programs are billed using the Physician Fee Schedule and fall under the E&M codes, information received by NAHC indicates that the financial impact of CMS’ planned changes on hospices and on palliative care programs that bill under Part B will vary significantly depending on an entity’s practice.

Source: NAHC Report

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