CMS Delays E/M Payment Changes to 2021 in Fee Schedule Final Rule CMS Delays E/M Payment Changes to 2021 in Fee Schedule Final Rule

CMS Delays E/M Payment Changes to 2021 in Final Rule for 2019

On Nov. 1, the Centers for Medicare and Medicaid Services (CMS) released the 2019 Final Rule. The rumors that reimbursement changes and documentation relaxation would not be implemented turned out to be only partially true. CMS did include them in the Final Rule for 2019, however, implementation is delayed until 2021.

The document is extensive, a full 2,000 pages. Below are key points and the ones that have the strongest impact on pro-fee providers and support teams.

What You Need to Know About CMS’ Final Rule for E/M Reimbursements
  • The blended reimbursement rate for E&M levels of service 99202-99204 and 99212-99215 will be implemented in 2021 – so you have 2 years to ramp up. The level 5 service is NOT included in this blended rate due to concerns of care for complex patients being impacted.
  • The 25 modifier change did NOT pass on the Final Rule for 2019. The Proposed Rule would have slashed reimbursements for these combined services, however, this did not pass (and many providers are breathing a sigh of relief).
  • The G codes proposed for podiatric services were NOT formally adapted as part of the Final Rule.
  • The proposed new G codes for Primary Care Services, Specialty Services, and Extended Care (formerly known as Prolonged Physician Services) were accepted as part of the Final Rule for implementation in 2021.
  • Documentation relaxation was also adopted for implementation in 2021. This includes the use of ancillary staff within the creation of outpatient office based E&M services, documentation requirements reduced to that of a level 99202/99212 encounter.

We encourage you or one of your staff to read the actual rules instead of relying on interpretations or opinions of what is and is not included. It’s a lot of information to digest all at once, so carve out some time each day to work through it.

Click here to view the CMS 2019 Final Rule

What to do next…

  1. Contact us to discuss your coding and documentation needs by calling (800) 635-4040 or email
  2. Read more: What can you expect from a coding and compliance review?
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