2019 MPFS proposed rule includes updates to E/M reporting and removal of certain QPP quality measures

Thursday, July 19, 2018

The 2019 Medicare Physician Fee Schedule (MPFS) proposed rule, released July 12, introduces policies that focus on expanding the framework for reporting E/M visits and removing certain process measures under the Quality Payment Program (QPP). 

CMS proposes to lower the add-on payment for wholesale acquisition cost (WAC)-based payments for new Part B drugs to 3% in place of the current 6%. According to CMS, reducing the add-on payment to 3% of WAC will help curb excessive spending by better aligning payments and drug acquisition costs.

The proposed rule includes several revisions to coding and payment policies intended to reduce administrative burden and improve payment accuracy for E/M office and outpatient visits. Notable updates include:

  • Allowing providers to review and verify certain documentation submitted by staff or the beneficiary, rather than re-entering it.
  • Restructuring the current framework for reporting E/M visits. According to the rule, providers have the option to either document office/outpatient E/M visits using time and medical decision-making or using the 1995 or 1997 E/M documentation guidelines. Additionally, providers can to use time as the governing factor in selecting visit level, regardless of whether counseling or care coordination dominate the visit.
  • Rethinking how medical history and exams should be documented. Providers should focus on what has changed since the patient’s last visit rather than re-documenting information, according to the rule.

According to the proposed rule, the 2019 MPFS conversion factor is $36.05— a slight increase from the 2018 conversion factor of $35.99.

The proposed rule also includes updated policies for year three of the Quality Payment Program (QPP). Changes to the QPP will affect providers enrolled in either the Merit-based Incentive Payment System (MIPS) or an Advanced Alternative Payment Models (Advanced APMs). Documentation submitted for calendar year (CY) 2019 will have a payment impact in 2021.

A few key QPP proposals include:

  • Expanding the definition of MIPS-eligible clinicians to include physical therapists, occupational therapists, clinical social workers, and clinical psychologists  
  • Overhauling the Promoting Interoperability performance category proposed for hospitals in the IPPS proposed rule, to support greater EHR interoperability and patient access 
  • Removing MIPS process-based quality measures that the agency has deemed are low-value or low-priority to focus on measures that may have a greater impact on health outcomes  

CMS released a fact sheet detailing these and other proposed changes for year three of the QPP.

CMS also released a fact sheet that provides an overview of all the 2019 MPFS updates. The proposed rule will be published in the Federal Register on July 27. Comments can be submitted to CMS until 5 p.m. on September 10.


Editor's note: This story was originally posted on JustCoding.