09/05/2018

ASK MSHO

September 2018, Frequently Asked Questions

Question: We have heard a lot about the Medicare Proposed Physician Fee Schedule for 2019, especially on the office visit changes.  My office wants to submit comments online but I can’t find where to submit them.  Also, does it have to be the doctor or can an administrator submit comments?

Answer: ANYONE may submit comments regarding the changes.  You can submit electronically at;  http://www.regulations.gov and put “1693” in the search at the top.  You’ll see:

Medicare Program: Revisions to Payment Policies under the Physician Fee Schedule and Other Revisions to Part B for CY 2019; Medicare Shared Savings Program Requirements; etc. 

Look to the right and you’ll see, “Comment Now!”  Then follow the “Submit a comment” instructions.

You can also submit comments;

• By regular mail. You may mail written comments to the following address ONLY: Centers for Medicare & Medicaid Services, Department of Health and Human Services, Attention: CMS-1693-P, P.O. Box 8016, Baltimore, MD 21244-8016.
• By express or overnight mail. You may send written comments to the following address ONLY: Centers for Medicare & Medicaid Services, Department of Health and Human Services, Attention: CMS-1693-P, Mail Stop C4-26-05, 7500 Security Boulevard, Baltimore, MD 21244-1850.

In commenting, please refer to file code CMS-1693-P.   Please allow sufficient time for mailed comments to be received before the close of the comment period September 10, 2018 at 11:59 pm eastern time.

Question: I know Medicare is proposing to change the documentation and billing for office visits next year.  Do you know if this applies to our hospital visits too?

Answer: The proposed E/M changes would apply to office/outpatient visit codes (CPT 99201 – 99215).  CMS states they may expand to other sections of the E/M codes in future years.

Question: I heard that Medicare is proposing that we can document a level 2 visit next year regardless of the level we are billing.  Some of our visits are billed based on the time spent with the patient, will we still be able to bill based on time?

Answer: Medicare is proposing to give the physician 3 options related to their documentation requirements, keeping in mind that a physician can document more if they choose but it is not required;

1. Document using the 1995 or 1997 guidelines at least the level 2 visit requirements
2. Document just the Medical Decision Making equivalent to a level 2 visit
3. Choose level based on time and require the practitioner to document the medical necessity of the visit and show the total amount of time spent face-to-face with the patient, “regardless of the amount of counseling and/or care coordination furnished,” as part of the face-to-face encounter.

Currently when billing a visit based on time, you are required to document that counseling and/or care coordination furnished was more than 50% of the time spent with the patient.  Medicare is proposing to remove this portion of the documentation requirement.

Question: Medicare is proposing to reduce documentation requirements for our visit codes next year.  Do you know if this will change AMA CPT and the requirements by other payers?  If they don’t change are we supposed to teach our physicians two different ways to document?

Answer: No, the AMA CPT rules are not changing and therefore the requirements by private payers are not likely to change.  It will be challenging to document one way for your Medicare patients and stick to the current rules for documentation for private payers.  

Question: Is it true that Medicare is proposing to pay the same amount for office visits regardless of the level of service billed?  That is ridiculous!  

Answer: Yes, below are the proposed rates for office visits;

• New Patient Visits;
  • 99201 = $44.00 
  • 99202 – 99205 would be reimbursed at a rate of $135.00
• Established Patient Visits;
  • 99211 = $24.00
  • 99212 – 99215 would be reimbursed at a rate of $93.00

Question: How is it possible that Medicare is proposing to pay less for our level 3 – 5 visits next year!!!  We spend a lot of time with our complicated oncology patients!!

Answer: Medicare stated they took into account those that regularly bill higher level of service and created an “add on” code for primary care and specialists;

• GPC1X for primary care
  • worth about $5.00 additional 
  • can be used only with established patient visits, 
• GCG0X,
  • (Visit complexity inherent to evaluation and management associated with endocrinology, rheumatology, hematology/oncology, urology, neurology, obstetrics/gynecology, allergy/immunology, otolaryngology, cardiology, or interventional pain management-centered care
  • which will add approximately $14.00
  • can be used with each visit on new and established

Question: I hear there is a new prolonged visit code proposed for next year.  We already have a prolonged visit code, what is the difference?

Answer: A new prolonged services code, GPR01 is proposed to be established for care 30 minutes beyond the typical time for the base code. (The existing prolonged codes have a 60 minute threshold).  Reimbursement for this code will be approximately $67.00 and can be billed with the visit code and specialty complexity of care code.