8/8/18 NAMAS Webinar CMS Proposed E&M Changes

Post here your questions regarding auditing ,coding, documentation, and compliance. Also, join in on the conversation- help your fellow auditors and compliance professionals in the industry.

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Thu Aug 09, 2018 10:21 am

Hello all,

Thank you for attending our CMS Proposed E&M Changes webinar yesterday! For those of you who asked questions live and were unable to receive answers, Shannon has responded to each and the list is compiled below. If you have any follow up questions, please feel free to contact the speaker directly or send them to us at namas@namas.co. Thank you!

Disclaimer: These questions were copied and pasted without and editing for grammar, spelling, or clarity, directly from the webinar Q&A feed. The answers were compiled after the fact by the webinar speaker and answered in line, per question.

1. Could you explain to us in your professional opinion how this proposed rule will effect our jobs in a positive and negative way? With less documetion requirements and equal payment amounts for differnt levels of service, I feel like its going to effect the coding and auditing industry in a negative way.
My humble opinion, yes it will impact our sector of the industry for the exact reasons you mention. If documentation has essentially no compliance requirements and does not impact the level of service billed for this code set then the need for coders/auditors might be impacted. Yes, they will still be needed for other E&M service and procedures/surgeries- but E&M are about half the codes billed to Medicare and of that about half of those are these codes.

2. I see every physician using the add-on G codes on all patients.... so will they make frequency rule you think?
Interestingly enough, the primary care G code information indicates that they would expect it to be used routinely on established patient encounters. However, on the specialty G code it does not specific this nor does it indicate the choice that would be made of when to add it and when not too. We will have to wait for further guidance.

3. Does this affect FQHC’s?
These guidelines do not specific any place of service, but rather the code sets involved. Since a FQHC uses this code set, then I would assume the dcouemtnation relaxation would apply, but I would think your reimbursement process might remain intact- as it is already at a flat rate reimbursement.

4. Have you seen any other documentation regarding Dr. Kate Goodrich, CMS' CMO regarding an add on code of $67 for those providers who need more time for their E/M visits. I have only seen it one time in an article from Kaiser.
No, I have not, but I would assume that this is referring to the add-on code proposal as the reimbursement is about $67 and the key phrase of providers needing more time

5. How will this impact Rural Health Care since they are already paid by All Inclusive Rate? What is the benefit of being a RHC if the AIR rate is lower than what is proposed in this flat rate for FFS Medicare?
This remains to be seen as the proposed guidance does not address places of service but only the code set reimbursement/documentation proposed guidance.

6. Will the "G" codes only apply to Medicare?
Well, this is CMS proposed guidance. If it becomes final rule- we will likely then hear about any commercial insurances accepting or not allowing these codes.

7. When reviewing records for claims payment or other audits, a lot of history supports the med nec. Getting only interim updates, and not the whole picture of the patient's condition may not support med nec.
Very true

8. Is CMS saying only documenting to level 2 is safe for patients ..... seems like allowing the providers to be lazy ( work level 4 or 5 w/ documentation level 2) and risking patient safety.
I challenge that providers are FAR FROM lazy. The proposed rule does not address patient safety, patient care, or continuity care, but personally- yes I agree it certainly could impact patient care.

9. If you are a provider who only documents on time for every patient, will the lax in documentation cause the amount of time spent with the patient to also decrease with this proposal?
Well, the new time provision indicates they would need to document the time spent face to face and support the medical necessity for the encounter and that is it- no additional requirements according to the proposal

10. If a patient is seen for less than the threshold (16 or 29 mins), is th3e se4rvice not billable? Why would we need to code to a level at all?
Haha- quite an excellent point. If they didn’t reach the threshold then they would have to support the visit by MDM (only), or by the current documentation framework of a level 2 encounter. And, you are right- I think there would be much confusion then by a coder as to- ok--- which code do I pick the 2, 3, 4, or 5

11. How would secondary insurance be billed, because we know not all insurance plans will adopt the new G-codes?
That will remain to be seen. In the past when CMS has made such changes you would have to file CMS- get the payment- then modify the claim and file the secondary. Again, something we will have to wait and see what happens.

12. Does these proposed change only affect outpatient office codes? Does it include inpatient visit codes?
Outpatient office code set only

13. is there any proposal to eliminate the 1995 guidelines
Not at this time, just to relax some of the documentation requirements

14. Can you talk about the proposed 50% reduction for modifier 25 when an E/M and procedure billed on the same day.
Yes, I think this is getting lost in all of the conversations of the E&M changes. I think this is their way of saying well- we gave you rules on how to use 25 modifier and when to use it- you cannot figure it out- so moving forward- bill away- we will just reduce your reimbursement. And what really stinks are those patients that we TRULY handle a full problem and the procedure and NOW no reimbursement for both issues.

15. Has a system similar to DRG (based on dx) been considered?
I am not sure as this is not mentioned in the final rule

16. Does the GPR01 Prolonged Physician Services cover those in a speciality practice?
Yes- as proposed it will cover any specialty

17. Will this also affect visit done by Telemedicine physicians
That was not addressed in the proposed guidance- but I would suppose so—we will have to wait to see on that one

18. Do you think commerical carriers would follow this if it goes through? If it goes through, and they don't, then wouldn't it cause a lot of problems for providers who submit claims for Medicare & Commercial? I would think commerical would still want to see the documentation and the providers might not be doing it when billing for higher codes.
Well, I’m on the fence on this one. as to the secondary cross over- this has happened before were CMS coding was differenct and we had to file them, get the claim paid, modify the coeding and resubmit- so I don’t think that will weigh into their decision. As to the commercials though- look it would save them money to go to a flat rate reimbursement- sooooo, I can see them following eventually.

19. What is shannon's opinion on how this would effect a Spine surgeon that doesnt use a PA to complete work up on patients, he does all the work himself,
The administrative burden of the documentation will be lessened, but so will his reimbursement for those services.

20. What about time not needing to be counseling and co-ordination of care?
This would be eliminated. There would no longer be the requirement for counseling and coordination of care.
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