Drum Roll: What Does MPFS 2019 Final Rule Say About E/M?

Medicare released the CY 2019 Medicare Physician Fee Schedule (MPFS). One of the big questions from the proposed rule was whether E/M payment rules would change. Here are some highlights on what made it into the final rule for E/M and what didn’t.

The News You’ve Been Waiting for …

The proposal to combine payment rates for E/M levels two to five (meaning they would all pay the same) has been postponed and will likely look different when a change happens.

The new plan is that, in 2021, Medicare will start paying a single rate for office/outpatient E/M levels 2 to 4 (such as 99212-99214). Level 5 will still have its own rate.

As the move toward this plan continues, stay alert for related changes in 2021. For instance, watch for a change allowing practitioners to document office and outpatient E/M levels 2 to 5 using only medical decision making or time. There’s also a plan for new add-on codes to represent additional resources and time for certain medical care, like primary care. The primary codes are expected to be office/outpatient level 2 to 4 codes.

Adjust Home Visit Rules

CMS has removed the requirement to document medical necessity of furnishing a home visit (99341-99350) rather than seeing the patient in the office. Start on page 554 of the final rule PDF for this discussion.

Re-record Is Out, But Provide Evidence of Review

As of Jan. 1, 2019, Medicare will not require practitioners to redocument history and exam elements, such as review of a specified number of systems and family/social history, if the information is already present in the medical record. But the practitioner does need to review that information, make any necessary updates, and indicate that work in the medical record.

Check page 571 of the PDF under “Removing Redundancy in E/M Visit Documentation” for this discussion.

Keep scrolling down to page 574 of the PDF, and you’ll see that Medicare also will allow the practitioner to note review and verification of the chief complaint and history entered by ancillary staff or the beneficiary. The practitioner does not need to re-enter it.

Note: Continuing current documentation practices is OK, too. That gives you time to learn the changes, train everyone involved, and adjust workflow.

What About You?

Are you glad to see these documentation changes and the potential for E/M changes to come? How will you prepare?



Deborah works on a wide range of TCI SuperCoder projects, researching and writing about coding, as well as assisting with data updates and tool development for our online coding solutions. Since joining TCI in 2004, she’s covered the ins and outs of coding for radiology, cardiology, oncology and hematology, orthopedics, audiology, and more.

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