- Proposed changes for the 2019 Physician Fee Schedule would effectively put “patients over paperwork,” helping to deliver on a promise from CMS to improve patient-centered care and patient care access, said the American Medical Association in a recent comment letter.
In its 2019 Physician Fee Schedule proposal, CMS says it reduced administrative burden with the intent of allowing providers to focus more on their patients. CMS proposed to ease up on some documentation requirements for evaluation and management (E/M) services, reducing clinical note overload, AMA and about 160 of its industry peers wrote.
“Excessive E/M documentation requirements do not just take time away from patient care; they also make it more difficult to locate medical information in patients’ records that is necessary to provide high quality care,” the signatories explained. “Physicians and other health care professionals are extremely frustrated by ‘note bloat,’ with pages and pages of redundant information that makes it difficult to quickly find important information about the patient’s present illness or most recent test results.”
The proposed 2019 Physician Fee Schedule would eliminate the need for providers to document patient history outside of the interval history since the patient’s previous visit. Additionally, the proposal would eliminate the requirement for physicians to re-document patient data that has already been entered into the EHR. Finally, the rule would remove the need to justify providing a home care visit.
However, AMA and its peers did take some issue with the proposals, specifically those that call for reducing multiple payments into one.
“We oppose the implementation of this proposal because it could hurt physicians and other health care professionals in specialties that treat the sickest patients, as well as those who provide comprehensive primary care, ultimately jeopardizing patients’ access to care,” the letter states.
AMA and the other signatories acknowledged that reconfiguring the E/M service codes is a complicated process, and recommended CMS develop a physician and healthcare professional workforce to identify the best solutions to issues facing CMS. Ideally, the workgroup would develop solutions for the 2020 Physician Fee Schedule proposals.
“We encourage the administration to adopt in the final rule the documentation changes outlined above,” the letter concludes. “These changes reflect significant progress in your Patients Over Paperwork Initiative. Such policy modifications will significantly reduce the documentation burden so health care professionals can spend more time with patients.”
Other medical groups also took issue with parts of the proposed payment rule, stating that it could harm providers who treat complex patients and reduce patient access to care. Specifically, a letter from the American College of Rheumatology and 126 other leading patient advocacy groups questioned a proposal to consolidate billing codes.
Consolidation of billing codes means there would be fewer specific codes from some patient care interactions. The signatories argue that this change, while well-intentioned, would pay a flat rate for office visits, regardless of patient acuity.
This would especially impact specialty care providers, as well as some primary care providers.
“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 group continues.
The proposed changes would also harm providers who treat patients who are sicker or who have multiple chronic conditions. These issues could serve as a dis-incentive for providers to treat this population, adversely affecting patient care access.
“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 concludes. “We therefore urge CMS not to move forward with the proposal as it currently stands, and instead convene stakeholders to identify other strategies to reduce paperwork and administrative burden that do not threaten patient access to care,” the letter concludes.