On July 12, 2018 CMS issued proposed a rule that includes changes to E/M documentation and reimbursement. If implemented, this will reduce the documentation burden, but it will also decrease reimbursement and wRVU’s for E/M level 4 & 5 office visits for new and established patients. It will eliminate levels of visits and have only a new patient and a follow up visit reimbursed at approximately a level 3 visit in ambulatory care. Typically providers in outpatient Palliative Care clinics bill at a level 4 or 5. If these changes are made, there are potentially significant financial ramifications for clinic-based palliative care.
It is imperative that Palliative Care providers comment on this proposed rule. The comment period closes on September 10th. Here is an excellent article that spells out the concerns for Palliative Care.
Below is a very brief summary of the proposal as it affects E/M documentation and payment.
Documentation Proposals – positive impact
Payment Proposal – negative impact
Organization Impact – negative impact