E/M on the horizon: Payment, coding, and documentation changes to come

December 4th, 2018

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Note:  The following article synopsis was NOT provided by HCPro. It was created by Find-A-Code/innoviHealth.

Article Overview

This article explains CMS’s evolving plans for evaluation and management (E/M) office and outpatient services under the 2019 Medicare Physician Fee Schedule final rule. It is relevant to physicians, coders, practice managers, and compliance teams who need to track upcoming Medicare payment structure changes, documentation options, and related guidance from CMS and other stakeholders.

Why This Topic Matters

The article helps readers understand a major federal reimbursement and documentation policy shift affecting commonly billed E/M services. It summarizes the categories of changes CMS discussed, the implementation timeline, and the broader policy context so practices can evaluate operational impact.

Article Sections

  1. CMS delays and revises planned E/M changes

    Background on the timing of CMS’s proposed and final decisions, including the revised implementation schedule and the broader policy context. The section frames how the agency’s final rule differed from earlier proposals.

  2. Three payment buckets for E/M codes

    Discussion of the planned E/M payment structure and how CMS organized office/outpatient services into separate payment groupings. The section also addresses the role of AMA and CPT Editorial Panel activity in the future of the code set.

  3. Choose-your-own medical documentation guidelines

    Summary of CMS’s documentation framework options and the concerns raised by commenters about variation, audit review, and record standards. The section covers the broader documentation policy changes and stakeholder reactions.

  4. Primary care and specialty add-on codes

    Explanation of CMS’s proposed add-on concepts for certain visits and the specialty groups referenced in connection with them. The section focuses on how these additions fit into the broader E/M payment redesign.

  5. New option for extended service time

    Overview of the separate time-based option discussed for longer E/M or psychotherapy encounters. The section covers the general framework for the service-time concept and its relationship to office/outpatient settings.

What You Will Learn

  • How CMS’s E/M office/outpatient payment structure was expected to change
  • What documentation framework options CMS discussed for future E/M reporting
  • Which broad categories of visits and specialties were addressed in the final rule
  • How CMS framed extended service-time reporting within the E/M discussion
  • Why stakeholders were paying close attention to the Medicare Physician Fee Schedule timeline

Who Should Read This

  • Medical coders
  • Physicians
  • Practice managers
  • Compliance professionals
  • Billing staff
  • Revenue cycle teams

Codes Discussed

  • CPT: 99212
  • CPT: 99215
  • CPT: 99201
  • CPT: 99205
  • HCPCS Level II: GPC1X
  • HCPCS Level II: GCG0X
  • HCPCS Level II: GPRO1

Code Ranges Discussed

  • CPT: 99212-99215
  • CPT: 99212-99214

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