Summary of Potential E/M Documentation & Coding Changes Discussed in CMS 2019 Final Rule

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.