January 2019 Client Newsletter
2019 Medicare Deductible
The Part B deductible increases slightly to $185.
CMS Physician Fee Schedule for 2019 Changes to E&M Code Documentation
New documentation rules have cut physician administrative burden. CMS followed AMA suggestions as well as some 170 other medical groups in a letter sent to CMS Administrator Seema Verma.
- Physicians will not have to redocument elements of a patient's medical history and physical exam. Instead, documentation will focus on patients' medical history during the interval since the previous visit.
- Gone is a requirement that physicians redocument information recorded by their staff or by the patient.
- In addition, a requirement to document the medical necessity of furnishing a home visit rather than an office visit has been eliminated.
Annual Wellness Visits - New vs. Established Patients
Reminder: When using the AWV codes for non-Medicare patients - 99381-99387 and 99391-99387, be sure to use them correctly.
The 99381-99387 are ONLY for NEW patients to your practice (cannot be used for an Established patient but who has not yet received their first AWV). The CPT Description is as follows:
"Initial comprehensive preventive medicine evaluation and management of an individual including an age and gender appropriate history, examination, counseling/anticipatory guidance/risk factor reduction interventions, and the ordering of laboratory/diagnostic procedures, new patient."
The 99391-99397 are ONLY for ESTABLISHED patients in your practice. The CPT Description is as follows:
"Periodic comprehensive preventive medicine reevaluation and management of an individual including an age and gender appropriate history, examination, counseling/anticipatory guidance/risk factor reduction interventions, and the ordering of laboratory/diagnostic procedures, established patient."
E&M Guidelines are stated as follows (emphasis added):
"Solely for the purposes of distinguishing between new and established patients, professional services are those face-to-face services rendered by physicians and other qualified health care professionals who may report evaluation and management services reported by a specific CPT code(s). A new patient is one who has not received any professional services from the physician/qualified health care professional or another physician/qualified health care professional of the exact same specialty and subspecialty who belongs to the same group practice, within the past three years.
An established patient is one who has received professional services from the physician/qualified health care professional or another physician/qualified health care professional of the exact same specialty and subspecialty who belongs to the same group practice, within the past three years."
So, once you have provided an E&M service to a patient within the past 3 years, you can only use the 99391-99397 series based on the patient's age. Given that guidance from the CPT Guidelines, if a patient sees you for the first time for a "problem" - you can only use 99381-99387 if the patient receives the AWV service during the first visit.
On Call or Other Coverage for the Provider:
"In the instance where a physician/qualified health care professional is on call for or covering for another physician/qualified health care professional, the patient's encounter will be classified as it would have been by the physician/qualified health care professional who is not available. When advanced practice nurses and physician assistants are working with physicians they are considered as working in the exact same specialty and exact same subspecialties as the physician."
CMS - Final 2019 Payment
On November 1st, the Centers for Medicare & Medicaid Services (CMS) released the final 2019 Physician Fee Schedule (PFS), which includes payment updates and modifications to the Merit-based Incentive Payment System (MIPS) reporting requirements and alternative payment model (APM) participation options starting Jan. 1, 2019. The final rule includes the following key changes:
- Sets the CY 2019 PFS conversion factor at $36.0391.
- Makes changes to E/M payment rates starting in CY 2021 by collapsing E/M office visit levels 2 through 4 for established and new patients, while maintaining a separate payment for level 5 visits.
- Creates new covered codes for technology-based services, including virtual care and remote patient monitoring codes.
Outlines changes to MIPS reporting requirements, including a requirement for clinicians and practices to adopt 2015 edition Certified EHR Technology for Promoting Interoperability reporting.
After consideration of concerns raised by commenters in response to the proposed rule, CMS is not finalizing aspects of the proposal that would have: (1) reduced payment when E/M office/outpatient visits are furnished on the same day as procedures, (2) established separate coding and payment for podiatric E/M visits, or (3) standardized the allocation of practice expense RVUs for the codes that describe these service.
For Physical Therapy, functional status reporting will be discontinued after December 31, 2018.
Payment Rates for Non-excepted Off-campus Provider-Based Hospital Departments Paid Under the PFS will be significantly decreased to 40% of the Outpatient Prospective Payment System (OPPS) to encourage fairer competition between hospitals and physician practices by promoting payment alignment between outpatient settings.
For more information, you can review the physician payment fact sheet and QPP fact sheet associated with the 2019 final PFS. MGMA will analyze the final rule and provide a detailed analysis as a member benefit.
Provider Enrollment Fee for 2019 - EMS & DME Providers
CMS announced the provider enrollment application fee for 2019 will be $586. This fee applies to providers newly enrolling in the Medicare program as well as provider revalidations. This is a slight increase from the 2018 enrollment fee of $569. The enrollment application fee applies to "institutional" providers that are:
- Initially enrolling in the Medicare or Medicaid program or the Children's Health Insurance Program (CHIP).
- Revalidating their Medicare, Medicaid, or CHIP enrollment.
- Adding a new Medicare practice location.
An "institutional provider" for purposes of Medicare is defined as "(a)ny provider or supplier that submits a paper Medicare enrollment application using the CMS-855A, CMS-855B (not including physician and non-physician practitioner organizations), CMS-855S, CMS-20134, or associated internet-based PECOS enrollment application." This fee is required with any enrollment application submitted from January 1 through December 31, 2019.
- Requiring EFT - Effective January 1, AmeriHealth will require participating providers to receive payments via electronic funds transfer. (Read More).
Reducing Co-Pay for Telemedicine - Effective January 1, AmeriHealth will reduce the co-payment for telemedicine services to 50% of an in-person office visit. (Read More)