Proposed Rule?

Here are some questions I have received when discussing the Proposed Rule with providers:

Q. Why is CMS proposing these changes?

A. CMS launched the “Patients over Paperwork” initiative in December of 2017 with the goal of cutting red tape and reducing burdensome regulations. The burden of proper documentation to support E&M code levels has been a frequent complaint by providers. CMS wants to take that burden away so the provider can focus more on patient care. It has been reported that on average, a provider spends over 50 hours a week doing unnecessary documentation.[1]

Q. If we are only getting one fee for an established visit and one fee for a new patient, why should we do all this documentation?

A. Unfortunately, many providers are so wrapped up in the documentation requirements and reimbursement issues, they seem to have forgotten the basic purpose of the note….the patient, their condition and treatment plan. What is their complaint and/or condition and what needs to be done about it?

Providers should reevaluate how they are utilizing their EMR. EMR drop downs should never replace the providers’ written assessment of the patients’ condition and their treatment plan. Clinical information pertinent to the present conditions must be documented in the note. For many of the notes we review this is missing because providers are utilizing templates that are lacking or just prefer to “click thru” their note.

Q. Why do I care about changes in the Final Rule, I only deal with a few codes?

A. The final rule includes changes in reimbursement, new codes and how they will be covered by CMS. A service you provide, but were never able to bill for may be included in the final rule. Someone from your offices should review the changes on a yearly basis.

Q. When will the proposed rule be final?

A. The final rule is typically published during the first week of November.


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