Medicare Physician Fee Schedule: 2018 Proposed MPFS Suggests Revising 1995 and 1997 E/M Documentation Guidelines

Why This Topic Matters

The topic affects how evaluation and management services may be documented and evaluated under Medicare policy, which can influence clinical workflow, compliance concerns, and documentation practices across specialties.

Article Sections

1. CMS proposal and comment period

   Introduces the proposed Medicare policy changes and the public comment timeline. Sets up the broader context for the documentation guidance discussion.

2. Why CMS may revise the E/M guidelines

   Summarizes stakeholder concerns and CMS’s stated reasons for considering updates to the documentation framework. Discusses broader issues such as burden, ambiguity, and technology changes.

3. Dig into possible E/M comment areas

   Outlines the main areas CMS is asking the public to weigh in on. The discussion focuses on documentation expectations, specialty impact, and the degree of physician discretion.

4. Area #1: History and exam documentation

   Covers the proposal to reduce or eliminate certain documentation requirements and the discussion around alternative factors used to distinguish visit levels. Includes practitioner commentary on practical implications.

5. Area #2: Specialty impact

   Addresses CMS’s interest in understanding how changes may affect different specialties. Emphasizes the role of specialty-specific practice patterns in the comment process.

6. Area #3: Physician discretion in documentation

   Discusses whether physicians should determine the extent of history and exam documentation themselves. Includes concerns about consistency, documentation support, and medicolegal risk.

7. Submitting comments and final rule timing

   Provides the deadline for submitting comments and notes that CMS plans to address them in a final rule. Also points readers to the proposed rule document.