MCMS Physician Fall 2017 - 15

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6. Evaluation and management (E&M) coding

9. Codes for Telehealth

Most clinicians that bill under the PFS use E&M visit codes
that distinguish things like level of complexity. CMS has heard
that these codes are outdated and would like feedback on updating
the guidelines to reduce administrative burden. In particular,
CMS is asking for comments on the appropriateness of removing
documentation requirements for the history and physical exam for
E&M visits at all levels, due to the increased use of EHRs and a
shift in focus to population health.

CMS proposes eliminating the modifier for telehealth services,
as well as adding several new codes to the list of telehealth services.

10. Stakeholder feedback is essential
CMS is asking for feedback in many areas, including:
* Solutions to achieve transparency, flexibility, program
simplification, and innovation;
* Whether emergency department (ED) visits are currently
undervalued under the PFS;

7. Appropriate use criteria for advanced
diagnostic imaging
CMS's Appropriate Use Criteria Program was set to begin in
2018, and CMS is now proposing to delay until Jan. 1, 2019.
The program would have denied payment for advanced diagnostic
imaging services unless the clinician consulted and reported the
use of appropriate use criteria, which are meant to assist clinicians
with making treatment decisions.

* Office-based laboratories' experiences with recent changes to
the Clinical Laboratory Fee Schedule.
PAMED members with questions about the proposed
2018 Medicare PFS can contact our Knowledge Center at
855-PAMED4U (855-726-3348) or KnowledgeCenter@
pamedsoc.org.

8. Payment rates for non-excepted off-campus
provider-based hospital departments (PBDs)
CMS proposes to set payment rates for services provided at
non-excepted off-campus PBDs at 25 percent of the Hospital
Outpatient Prospective Payment System (OPPS) payment rate
for 2018. This affects outpatient departments that were not
billing under the OPPS prior to Nov. 2, 2015, that are not
located within 250 yards of the hospital provider's main campus
or remote location. CMS believes this proposal "will encourage
fairer competition between hospitals and physician practices by
promoting greater payment alignment."

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Table of Contents for the Digital Edition of MCMS Physician Fall 2017
