CMS proposed moving away form the current documentation guidelines to a more time-based and complexity method.
Initially, the plan was to keep reimbursement the same for level 1 but for levels 2-5 the reimbursement would have been averaged. Meaning regardless if you did a level 2 or a level 5 the reimbursement would be exactly the same. But, due to the fact some subspecialties took action and expressed concern, CMS made a change. In the Final Rule, reimbursement will not change for level 1 or level 5. However, effective 2021, there will be an averaged/fixed allowed amount for levels 2-4. CMS is still open to review feedback on this change.
To learn more, please see: https://www.cms.gov/newsroom/fact-sheets/final-policy-payment-and-quality-provisions-changes-medicare-physician-fee-schedule-calendar-year