On July 12/2018 CMS proposed new documentation requirements and payment mechanism rule proposals for the upcoming year. While the proposed changes have not been accepted and implemented yet, physicians nationwide are weighing in on the potential positive and/or negative impacts that these proposed changes could impede on their practices.

While the proposed changes come partly as a result of physicians voicing their concerns on the documentation burdens that are required of them, it also comes with a slight caveat of potential financial repercussions that could make or break some practice’s bottom line.

These changes would indeed help to maximize the providers time in providing potentially more patient care for example by decreasing the need to re-document history information that is already present within the patient’s medical record, which is a current requirement to be able to assist in leveling the evaluation and management code presently. Measuring the medical decision making weight will fall more under these proposed rules on the assessment and plan portions of the chart.

Payment will be one set amount regardless of what office visit level is coded (Levels 1-5) at $135 for a new patient visit, and $93 for established.

While many physicians are praising and advocating for these changes, there are still as many who are taking a look at the bigger picture and concerned over their reimbursement compensating them fairly for the services that they provide. Physicians who have a complex specialty and who typically see ‘sicker’ patients than primary care for example could potentially suffer from the decreased reimbursement that may result due to the higher medical decision making typically involved in their patient’s care which allows them to bill at higher levels more often.

Practices should begin now to take a look of their prior year’s figures, and determine what their reimbursement would have been with these proposed payment rules vs. what they received at the traditional rates.  From there, a precise calculation of the overhead and expenses should be considered in order to determine if this would be beneficial or not, and if the changes take place, how appointments and expenses would be managed.

Providers and practices still have time to weigh in or the proposed changes through various healthcare organization websites and directly through the comment sections within the proposed rules published on CMS’s site, and it is imperative now that everyone’s voices be heard. Decreasing the administrative burdens may or may not be something beneficial, and without commentary from those that could be potentially affected in a negative way, there could be very little that can be done if and once the rules are implemented. Providing more patient care is important, however if a provider cannot afford to keep their doors open or compensate staff and ancillary companies that are involved, it will induce a negative impact and potentially decrease patient access to care.


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