E/M Final Rule: What your organization needs to do now

Aug. 16, 2019 / By Karla VonEschen, MS, CPC, CPMA

Can you feel change in the air? Not only is fall just around the corner, but so is the CMS change to E/M documentation and payment. By now, most of us who work in the wonderful world of coding are either acutely aware of or have at least been informed about the Patients Over Paperwork Act and changes coming in 2021. My colleague Jean Jones wrote a great blog  about the changes back in February of this year and touched on some “to-do’s” to get ready for the upcoming transition. Fellow blogger Barbara Aubry also gave her take on the changes earlier this week. Now it is my turn to share my ideas about what organizations need to do to prepare for the documentation and financial challenges they will be facing in approximately 16 months.

I like the phrase, “There is no time like the present,” especially when it comes to transitions in the medical coding world. You can either sit back and wait, with the knowledge that the proposed changes are more than a year away, or consider that change takes time and get started now. I’ve been doing this long enough to remember the implementation of Medicare Part D and ICD-10 and how painful the transition was for those who waited. With that in mind, here are some thoughts about what organizations can do now to start preparing:

• Committee – Get an internal committee organized to start the discussion around what steps are needed for your organization to be ready in 2021.
• Prioritize Initiatives – All organizations have competing internal initiatives; this change is big enough that you may need to discuss projects underway, projects coming up and what should be moved or put on hold to make sure you’re ready on January 1, 2021.
• Financial- In the initial proposal at the end of 2018, CMS had suggested collapsing payment for certain E/M codes which may or may not change before 2021.  Look at your financials now to be prepared for any potential impact to revenue. 
• Education – Simplification of medical decision-making (MDM) means physicians will need to be educated on these changes as well as what they will need to do to make sure notes contain supporting documentation. Coders will also need to be educated on internal changes to templates, documentation and any updates to internal policy.  Finally, educate yourself on the information sooner rather than later. 
• Communication – It’s often easier to appoint one individual as a point person for relaying communication from CMS and AMA. If you’ve been through a CMS change before, you know updates and communications can be fast and furious, causing a lot of confusion. Assigning one individual to review the communication and track updates as necessary may be beneficial by ensuring that everyone in the organization is on the same page and hears the same message. I recommend you bookmark the CMS website, Patients Over Paperwork website and the AMA website for E/M changes. The CMS website also allows you to sign up for email updates regarding these changes. 
• Decide on documentation – Discuss documentation options and decide which route your physicians will take, whether that means MDM, Time, or staying with the current E/M guidelines. Make a note of any internal policies and procedures that will need to be updated with these decisions. 
• Vendors – Communicate with your vendors that are impacted by this initiative. If your vendors aren’t ready for this change, it will impact your organization’s readiness.

For most of us, this is not our first rodeo and we know CMS can change direction within a moment’s notice. All impacted organizations must balance making decisions and initiating transition work now while keeping in mind this initiative could be delayed or certain elements changed before the final implementation. Change is coming whether we like it or not and the key to being prepared and ready is to not wait until the last minute!

Karla VonEschen is a coding analyst at 3M Health Information Systems.

CMS Patients Over Paperwork- https://www.cms.gov/Outreach-and-Education/Outreach/Partnerships/PatientsOverPaperwork.html

AMA CPT Evaluation and Management- https://www.ama-assn.org/practice-management/cpt/cpt-evaluation-and-management