The Takeaway From CMS 2019 Proposed Physician Payment Rule

On July 12, 2018, the Centers for Medicare and Medicaid (CMS) issued its annual proposed Medicare Physician Fee Schedule for 2019. Several key changes are included in this proposal, the most exciting of which is a requirement that physicians are paid for their time when they contact Medicare beneficiaries via telephone or other telecommunications channels to learn more about whether the patient requires an in-office visit or other procedure. Review the key takeaways from CMS’ 2019 proposed physician payment rule below and contact Jackson LLP to learn more about this new proposal and how it will impact your practice.

Increased Physician Payment Rates

In line with the Medicare Access and CHIP Reauthorization Act of 2015 (MACRA), the new proposal includes increasing physician payment rates by 0.25%, bringing the estimated physician fee schedule conversion factor up from $35.99 to $36.05.

Evaluation and Management Changes

Although evaluation and management (E/M) patient visits are the most common type of patient visit, they can also be the most confusing to code. Oftentimes, physicians try to err on the side of caution and code at a lower pay level than what they are entitled to, thereby losing revenue. One of the goals of the new CMS 2019 proposal is to make it easier for physicians and administrative staff to work through these codes and have a more streamlined and consistent coding structure. This will also improve payment accuracy for E/M visits and ensure that physicians are receiving the revenue they deserve.

One example of how the new CMS 2019 proposal will impact E/M coding accuracy is that it will allow physicians to review information on a patient’s record that was entered by the administrative team and other staff, so physicians can simply choose the code previously entered from the patient’s last E/M visit rather than re-entering a new code.

Telehealth Improvements

As mentioned above, CMS’ 2019 proposed physician payment rule adds a requirement that physicians be paid for time spent on the telephone or other teleconference medium with Medicare beneficiaries to learn more about what type of visit or procedure the patient requires. In addition to that, the new proposal also includes a provision that physicians must be paid for time spent reviewing an image or video from a patient to determine what type of visit or treatment the patient needs. 

The American Hospital Association has expressed its approval for most of the proposed changes in the 2019 physician payment rule. However, the organization has outwardly voiced disagreement over the site neutral payment policies, which would give off-campus facilities 40% of the Outpatient Prospective Payment System amount.

If you are looking for assistance with negotiating or reviewing your employment contracts under CMS’ new proposed physician payment rule, or guidance on the new telehealth rules, schedule your free consultation with an experienced healthcare lawyer at Jackson LLP. We can help guide you through the process of integrating the new policies into your practice. Schedule online now: