PROPOSED SINGLE-SET RVUs TO INCREASE PROFITS AND SIMPLIFY PRACTICES FOR MOST PRACTITIONERS
The Centers for Medicare and Medicaid Services (CMS) is suggesting significant change to the payment methods for evaluation and management (E/M) visits. These changes could take place as soon as January 1, 2019 and could affect every medical provider from Nurse Practitioners to Podiatrists and more.
As currently proposed, CMS would implement a single set of RVUs (relative value units) under the Physician Fee Schedule (PFS) for Level 2 through Level 5 E/M office-based and outpatient visits for new patients (CPT codes 99202 through 99205), and a single set of RVUs for Level 2 through Level 5 visits for established patients (CPT codes 99212 through 99215). The current proposed estimated rate under this scenario for new patients is $135 and for established patients, $93. Level 1 visits would remain unchanged and the proposed rate for those visits would be $44 and $24, respectively.
Under this proposed change, physicians will have less required documentation providing what CMS terms “immediate relief” for practitioners who feel bombarded with paperwork. CMS believes this will also reduce the likelihood of an audit for practices. For specialists and other practitioners who routinely bill primarily Level 2 or 3 E/M visits, CMS estimates these providers will, on average, see an increase in their reimbursements from the agency.
So, less paperwork and more money? Sounds great, right? For some, yes; for others, maybe not so great. Specifically Obstetrics/Gynecology providers are expected to reap the largest gains under the new proposal; many OB/GYN’s are projected to recognize a 3% to 4% increase in reimbursements due to this change. Dermatologists and Podiatrists are projected to see a -4% decrease, suffering financially perhaps the most; other specialties expected to receive reduced reimbursements are Otolaryngology (less than -3) and Rheumatology (-3%).
To offset potential revenue decreases for some practitioners, CMS is proposing to allow “add-on” payments for visits that have higher resource costs. For example, add-on codes would be available for separately identifiable E/M visits furnished in conjunction with a 0-day global procedure or for primary care visits provided in continuous patient care. Additionally, CMS proposes to eliminate the prohibition against paying for multiple E/M visits billed by the same physician or a physician within the same group practice in the same day.
In summary, while all practitioners probably welcome the idea of less documentation, not all will be satisfied with the potential revenue changes.
Because of the potential impact to workflow and EHR documentation, CMS is seeking comment on whether to delay the implementation until January 1, 2020. Comments are due by 5:00 p.m. on September 10, 2018.