More than 150 medical groups joined together with the American Medical Association in lauding some proposals in the 2019 physician payment rule that will decrease the administrative burden for physicians, but are raising alarm bells about a change to payment rates for some office visit services for both new and established patients.
The groups, which include the AMA, American Academy of Pediatrics, American College of Emergency Physicians, American Association of Orthopaedic Surgeons, American Chiropractic Association and numerous other groups wrote a letter to CMS Administrator Seema Verma applauding some proposals, but asked the agency to discard others.
As part of its "Patients over Paperwork" initiative, CMS has proposed as part of its 2019 Physician Payment Rule several documentation policy changes that the groups agree would cut down on administrative work and "note bloat" associated with evaluation and management services.
"Excessive E/M documentation requirements" take away from time with patients and makes it more difficult to locate medical information on patients that is needed deliver quality care. Physicians and other healthcare professionals have expressed significant concern over "note bloat," which results from copious redundant information that makes it difficult to quickly find important information about the patient's present illness or most recent test results.
The proposals include: changing the required documentation of the patient's history to focus only on the interval history since the previous visit; eliminating the requirement for physicians to re-document information that has already been documented in the patient's record by practice staff or by the patient; and removing the need to justify providing a home visit instead of an office visit.
"Implementation of these policies will streamline documentation requirements, reduce note bloat, improve workflow, and contribute to a better environment for healthcare professionals and their Medicare patients," the letter said.
The rule also contains a proposal to collapse payment rates for eight office visit services for new and established patients down to two each. The AMA and other groups expressed concern over unanswered questions and unintended consequences related to the coding policies in the proposed rule.
"We oppose the implementation of this proposal because it could hurt physicians and other healthcare professionals in specialties that treat the sickest patients, as well as those who provide comprehensive primary care, ultimately jeopardizing patients' access to care … The proposal also has significant impact on certain services, such as chemotherapy administration, that may be an unintended consequence of altering the current practice expense methodology to accommodate the proposal," the groups wrote.
Even more groups chime in, including patient and provider advocates
The proposal appears to be widely unpopular, as a second set of organizations, including more than 120 patient and provider advocacy groups led by the American College Rheumatology, have reached out to Seema Verma strongly opposing the proposal, saying it would consolidate billing codes for E/M office visits, resulting in a flat payment for all E/M visits regardless of the complexity of the visit.
Despite the intended purpose of reducing Medicare provider documentation and reporting burdens, the groups said it would trigger significant payment cuts for specialty care involving face-to-face visits with patients who have complex care needs, penalizing doctors who treat sicker patients or those with chronic conditions.
"We applaud CMS for recognizing the problems with the current evaluation and management documentation guidelines and codes and for including a significant proposal to address them in the CY 2019 physician fee schedule proposed rule," the letter reads. "However, we urge CMS to reconsider this proposal to cut and consolidate evaluation and management services, which would severely reduce Medicare patients' access to care by cutting payments for office visits, adversely affect the care and treatment of patients with complex conditions, and potentially exacerbate physician workforce shortages."
The groups warn that the proposed payment cuts would not only hinder access to care but could create a "disastrous ripple effect" throughout the U.S. healthcare system by dampening medical students' desire to practice in specialties that provide complex care, and also discourage doctors from taking new Medicare patients.
"Not only will this will result in an additional burden on patients with more copayments and costs associated with time and travel, it will also reduce the quality of care, particularly for patients with complex medical conditions," the letter continues.
In addition to the American College of Rheumatology and numerous other rheumatology related organizations, these groups also included the American Epilepsy Society, American Gastroenterological Association, American Heart Association and American Stroke Association, American Neurological Association, the Diabetes Patient Advocacy Coalition, National Headache Foundation, National Multiple Sclerosis Society and Schizophrenia and Related Disorders Alliance of America.