CMS floats changes to E/M coding, telemedicine, drug costs in 2019
Grant Huang, CPC, CPMA
Director of Content
You won’t look at E/M services the same way again if CMS finalizes some of the biggest changes in its 2019 Physician Fee Schedule (PFS) proposed rule. Following up on ideas it first voiced in the 2018 PFS rule, this time CMS has concrete proposals to simplify E/M services by minimizing the history and exam components while standardizing payment for outpatient E/M codes.
The PFS proposed rule, released July 12, weighs in at 1,473 pages, though some of those pages contain the 2019 proposed rule for Medicare’s Quality Payment Program (QPP). CMS usually publishes the QPP rules as separate documents, but this time they are bundled with the PFS proposed rule.
The biggest element of the QPP is the Merit-based Incentive Payment System (MIPS), which recently released its 2017 performance data, including payment adjustments for 2019. We will break down the key proposals in that rule in a separate story.
As for the PFS proposed rule, the E/M changes are getting the most attention, but the rule includes other important proposals as well. Below is our high-level overview of the top provisions that CMS wants to implement in 2019:
- 2019 conversion factor. CMS would set the 2019 conversion factor at $36.05, up slightly from $35.99 this year, keeping the change budget-neutral based on its calculations.
- New service types for ‘communication technology.’ CMS wants to introduce two newly defined services for physician care furnished using communications technology. The first would be a “virtual check-in” for brief use of communication technology and the second would be a “remote evaluation of recorded video and/or images submitted by the patient.” These would be assigned placeholder G-codes GVCI1 and GRAS1 respectively.
- Prolonged services added to telehealth. CMS wants to add existing prolonged service codes (G0513 for first 30 minutes and G0514 for each additional 30 minutes) to the list of telehealth-covered services.
- Reduce supervision requirement of radiologist assistants. In response to stakeholder comments, CMS proposes reducing the supervision requirement from personal (requires presence of physician) to direct (physician can be in the office suite but not in same room) for all diagnostic imaging tests performed by a radiology assistant (RA) in compliance with state scope of practice laws. CMS defines the RA designation as including registered radiologist assistants (RRAs) and radiology practitioner assistants (RPAs).