Proposed Changes to Impact Outpatient Palliative Care

Courtesy of Cynthia Tomik, WSHPCO Palliative Care Committee Chair:

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. 

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Below is a very brief summary of the proposal as it affects E/M documentation and payment.

Documentation Proposals – positive impact

  • Responding to the call to reduce the ever-growing administrative burden on provider
  • Changing documentation rules to use medical decision making or time instead of current guidelines.
  • Only document what has changed since last visit rather than re-documenting information.
  • Ability to review and verify certain information entered by ancillary staff or patients, rather than re-documenting the same information
  • Additional requirements for new “add on” codes and continued requirements for documentation of need for DME, etc

Payment Proposal – negative impact

  • New single blended payment rate for new and established patients for E/M level 2 through 5 visits.
  • New single wRVU for E/M level 2 through 5 visits.

Organization Impact – negative impact

  • Reduced reimbursement for office visits
  • Reduced wRVU’s for E/M levels 4 & 5 which will affect provider compensation.
  • Destruction of the current wRVU and compensation models

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