I have read through and it says that podiatrists and dermatologists are most affected. Everyone will be affected in some way.
I read that they are trying to decrease amount of paperwork and provide more time for physicians to spend with patients.
Isn't it a good thing? Isn't it what all physicians want?
Yeah, that's the good part about the changes.
The bad part is that they want to "require podiatrists to use different E/M codes than all other Medicare physicians, which would reimburse at a significantly lower rate" (so, DPMs will get much lower payment for the same procedure vs if a family med doc does it).
Let me post the letter that is being sent out to CMS from everyone concerned:
Dear Administrator Verma,
I write as a student of podiatric medicine (DPM) to ask CMS not to finalize its proposal to single out podiatric physicians by requiring DPMs use a separate and unique set of evaluation and management (E/M) codes that are different from what other Medicare provider uses, for the same E/M services, at a significantly lower rate of reimbursement. And, I oppose the proposal to collapse the existing E/M codes of 99202 through 99205 and 99212 through 99215 into two flat reimbursement payments for Medicare providers generally (except for DPMs). I also request that CMS not finalize the proposal to reduce reimbursement by 50% for the least expensive procedure or visit that the same physician (or a physician in the same group practice) furnishes on the same day as a separately identifiable E/M visit.
I will provide the exact same E/M services as my MD/DO colleagues, and I will be recognized as a physician on equal footing with MDs/DOs under Medicare, within my scope of practice. CMS’ proposal for separate payment for podiatric E/M services amounts to differential payment by specialty for the same E/M services provided by DPMs. CMS provides no explanation on how the evaluation and management required for patients seeking care from DPMs is distinct from that provided to patients seeking medical care from an MD/DO. Furthermore:
1. If a patient saw an MD/DO for a foot and/or ankle complaint, they would not be required to use these special codes.
2. The same documentation standards would apply for the new codes as those proposed for other providers’ office and outpatient E/M visits, suggesting that the services and clinical expertise provided in podiatry visits is comparable visits with other physicians.
3. CMS does not suggest that DPMs’ level of medical decision making is less than MDs/DOs, yet proposes this as a standalone basis for documenting E/M visits.
These factors clearly demonstrate that separate payment for E/M services provided by DPMs is not warranted, and that DPMs should be paid in the same manner and amount as all other Medicare physicians.
CMS’ proposal to collapse payment across Level 2 through 5 visits would reduce access to care for many vulnerable patients, leading to significant patient harm. I support CMS’ efforts to reduce administrative burden but I do not believe that this proposal would achieve this goal. Physicians will still spend the same amount of time with their more complex patients. CMS’ per visit payment would be insufficient to capture the full costs of furnishing this care. Thorough medical records are still necessary for these patients for purposes of completeness, safety, continuity of care, and risk management. None of that will change by decreasing CMS documentation requirements. These complex patients, a significant part of the Medicare population, frequently have multiple complications and require significantly more time and attention to properly treat. If this proposal goes through, the unfortunate reality is that many specialty Medicare physicians will likely face strong incentives to either limit care or require complex patients to return for multiple visits. CMS’ approach would apply a blunt payment that does not allow for more tailored care delivery. It would not decrease the amount of time I will spend with my future patients to thoroughly document their conditions or complaints.
I do not believe CMS has considered its proposals’ impacts on individual clinicians or practices. CMS only provided estimates broken down by specialty. However, patient health and population vary widely by region, even within a specialty. Practices that regularly manage or treat the most complicated patients would be especially harmed by insufficient reimbursement for complex visits.
CMS should continue its longstanding policy of providing consistent payment to all physicians, regardless of specialty and it should retain the current levels of E/M coding.
I also disagree with CMS’ assertion that separately identifiable visits occurring on the same day as a 0-day global procedure have significant overlapping resource costs. I strongly urge CMS to rescind this proposal.
According to CPT guidelines, modifier 25 is used to indicate a significant, separately identifiable, and medically necessary E/M service provided on the same day as a procedure. Providing medically necessary, separate, and distinct services on the same date of service allows physicians to provide effective high-quality care. Such services should be reimbursed appropriately and in accordance with established coding guidelines, whether used on the same date or different dates. This ensures that payments are sufficient to cover costs and leads to improved outcomes. More importantly, it makes it easier for patients who can avoid additional trips to the office and allows them to receive care that they need.
Thank you for your time and consideration.