2019 Fee Schedule: You asked. DWW answers.

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2019 Fee Schedule: You asked. DWW answers.

What are CMS’s plans for global codes? Evaluation and management payments and reporting requirements? What’s happening with modifier 25? Telemedicine reimbursement? Dermatology World Weekly answers your burning questions about the final 2019 Medicare physician Fee Schedule.

What are CMS’s plans for global codes?

This remains to be seen. In the July proposed fee schedule, CMS indicated that there is very low reporting of 99024 with codes that have 10-day global periods. As a result, CMS is trying to determine whether to eliminate the 10-day global period and replace it with a 0-day global period — which would negatively impact the values of many codes that dermatologists use.

CMS asked for guidance on ways to encourage reporting of 99204 and for methods for getting better information about post-op visits. They also questioned whether the post-op visits are taking place.

Per the AADA’s recommendations, CMS sent letters to the practices that are required to report 99024. The AADA strongly encourages any practice that received one of these letters to ensure that all post-op visits are reported. Reporting should continue until you are notified to stop.

CMS is also currently conducting a survey of randomly selected dermatologists, asking about post-op visits that occur with Complex Layered Closures. Read more about the survey in DWW. Academy members who receive this survey should call Helen Olkaba at 202-712-2612, or James Scroggs at 202-712-2617 for assistance.

Did CMS make changes to evaluation and management (E/M) payments?

CMS did not make any significant changes in fees for office E/M visits in 2019.

However, after Jan. 1, 2021, there will be a single consolidated payment rate for levels 2 through 4. Payments for level 1 and 5 will remain intact. The documentation requirements will also be reduced at that time. The impact of these changes on dermatology, as currently proposed, would be an increase in payment.

CMS is also finalizing add-on codes for primary care and nonprocedural specialized care complexity adjustment visits for CY 2021. The add-on codes, that account for inherent complexity in primary care and non-procedural specialty care, would only be reported with E/M office/outpatient levels 2 through 4 visits. These add-on codes would rarely be reported by dermatologists.

What changes did CMS make to E/M reporting requirements?

Effective Jan. 1, 2019, for new and established patients for E/M office/outpatient visits, physicians will not need to re-enter in the medical record information on the patient’s chief complaint and history that has already been entered by ancillary staff or the beneficiary. The practitioner may simply indicate in the medical record that they reviewed and verified this information.

Additionally, physicians may choose to focus their documentation on what has changed since the last visit, or on pertinent items that have not changed. Essentially, physicians will not need to re-record the defined list of required elements if there is evidence that they reviewed the previous information and updated it as needed. The AADA applauds this reduction in documentation requirements.

It should be noted that CMS plans to implement additional changes to documentation requirements in 2021 when the changes in E/M payment occur. CMS will allow billing practitioners the choice to use the current framework, medical decision making (MDM), or time.

Is CMS still considering a modifier 25 payment reduction?

CMS did not finalize the proposal to apply a reduction in payment when a separately identifiable office/outpatient E/M visit is furnished on the same day as a global procedure. This is excellent news for dermatologists. However, CMS has indicated that it will continue to consider how to address what they believe to be a problem of accurately accounting for duplicative resource costs. The AADA will continue to work with the AMA and other medical specialties to fight against this policy and to demonstrate to CMS that any duplicative costs have already been removed — a point CMS has made in previous rulemaking.

Will CMS reimburse for telemedicine services in 2019?

CMS made some progress increasing coverage of telehealth services, which they refer to as ‘Communication Technology-Based Services.’ This includes paying for GVCl1 — a virtual check-in with an existing patient — and GRAS1 — evaluation of images submitted by the patient.

CMS also finalized values for new CPT codes for Interprofessional Internet Consultation (CPT codes 99451, 99452) which is consistent with RUC recommendations. CMS is also proposing to unbundle and cover existing time-based CPT codes for remote consultation (99446, 99447, 99448, and 99449).

These are the complete code descriptions:

  • GVCI1: Brief communication technology-based service. For example, this includes a virtual check-in provided to an established patient by a physician or other qualified health care professional who can report E/M services. The service may not originate from a related E/M service that was provided within the previous seven days and cannot lead to an E/M service or procedure within the next 24 hours or soonest available appointment. Five to 10 minutes of medical discussion are required.

  • GRAS1: Remote evaluation of a recorded video and/or images submitted by the patient (i.e., store-and-forward telemedicine).

  • 99451: Interprofessional telephone/internet/electronic health record assessment and management service provided by a consultative physician including a written report to the patient’s treating/requesting physician or other qualified health care professional. Five or more minutes of medical consultative time are required.

  • 99452: Interprofessional telephone/internet/electronic health record referral service(s) provided by a treating/requesting physician or qualified health care professional. Thirty minutes of medical consultative time are required.

The Academy will continue to analyze the final 2019 Medicare Physician Fee Schedule as it prepares its official comment to CMS. Stay tuned to DWW for more updates and responses to your pressing fee schedule questions.