No separate codes for podiatric E&M visits in final rule.
The final rule for the 2019 Physician Fee Schedule was released on Nov. 1. Some of what was in the proposed rule was finalized, while other elements were either modified or completely eliminated. The proposal to reduce payment when evaluation and management (E&M) office and outpatient visits are furnished on the same day as procedures was not finalized. Also, in response to thousands of comments on this issue, the Centers for Medicare & Medicaid Services (CMS) did not finalize the proposal to establish separate codes for podiatric E&M visits. There are multiple significant changes to E&M services in the 2019 Physician Fee Schedule, however, some of which go into effect Jan. 1, 2019 and others that go into effect Jan. 1, 2021.
Effective Jan. 1, 2019: Through 2019 and 2020, providers will continue to use the CMS 1995 and 1997 Documentation Guidelines for Evaluation and Management Services to inform code selection for E&M services. Starting Jan. 1, 2019, for established patients, providers will be allowed to focus their documentation on what has changed since the last visit and will not be required to re-record any of the defined list of required E&M elements – as long as there is evidence that the practitioner reviewed the previous information and updated it as needed. For both new and established patients, providers will not need to re-enter information regarding the patient’s chief complaint and history into the medical record if it has already been entered by staff or the patient – if the provider indicates in the medical record that he or she reviewed and verified this information. Another significant change dealing with E&M services that goes into effect at this time will be that teaching physicians no longer will need to make notations in medical records that have already been included by residents or other members of the medical team. Finally, documenting the medical necessity of a home visit in lieu of an office visit will no longer be required.
Effective Jan. 1, 2021: New office and outpatient E&M services for CPT® codes 99202, 99203, and 99204 will all reimburse at a single payment rate. This rate will fall between what would have been the payments for CPT codes 99203 and 99204 in 2021. Established office and outpatient E&M services for CPT codes 99212, 99213, and 99214 also will all reimburse at a single payment rate, and this rate will fall between what the payment would have been for CPT 99213 and 99214 in 2021. Providers will be able to select the level of both new and established office and outpatient E&M services for levels 2 through 5 based on medical decision-making or time – or the CMS 1995 / 1997 Documentation Guidelines for Evaluation and Management Services. When using medical decision-making or the 1995/1997 guidelines to determine the level of an office or outpatient evaluation and management service, if the level is 2-4, providers will only need to reach the documentation threshold of a level 2 visit.
Also effective Jan. 1, 2021, there will be an implementation of add-on codes that denote the additional resources inherent in visits for primary care and particular kinds of non-procedural specialized medical care. These add-on codes will not be restricted by physician specialty, and they will only be reportable with office and outpatient E&M services of levels 2 through 4. Finally, there will be a new “extended visit” add-on code that can only be used with office and outpatient E&M services of levels 2 through 4, which will account for the additional resources required when practitioners need to spend extended time with a patient.
Resources
Revisions to Payment Policies under the Physician Fee Schedule and Other Revisions to Part B for CY 2019; Medicare Shared Savings Program Requirements; Quality Payment Program; Medicaid Promoting Interoperability Program; etc.:
https://www.federalregister.gov/public-inspection/current
Fact sheet on the CY 2019 Quality Payment Program final rule:
https://www.cms.gov/Medicare/Quality-Payment-Program/Quality-Payment-Program.html
Program Note:
Listen to Dr. Lehrman report on this topic today on Talk Ten Tuesdays, 10 a.m. ET.
Clinical documentation integrity (CDI) professionals work in a variety of settings, and although I mostly focus on topics related to hospital inpatient billing, this week
With so much focus within the federal government on abuse, fraud, and waste, I thought it might be helpful to review a couple of federal
Please log in to your account to comment on this article.
Accurately determining the principal diagnosis is critical for compliant billing, appropriate reimbursement, and valid quality reporting — yet it remains one of the most subjective and error-prone areas in inpatient coding. In this expert-led session, Cheryl Ericson, RN, MS, CCDS, CDIP, demystifies the complexities of principal diagnosis assignment, bridging the gap between coding rules and clinical reality. Learn how to strengthen your organization’s coding accuracy, reduce denials, and ensure your documentation supports true medical necessity.
Denials continue to delay reimbursement, increase administrative burden, and threaten financial stability across healthcare organizations. This essential webcast tackles the root causes—rising payer scrutiny, fragmented workflows, inconsistent documentation, and underused analytics—and offers proven, data-driven strategies to prevent and overturn denials. Attendees will gain practical tools to strengthen documentation and coding accuracy, engage clinicians effectively, and leverage predictive analytics and AI to identify risks before they impact revenue. Through real-world case examples and actionable guidance, this session empowers coding, CDI, and revenue cycle professionals to shift from reactive appeals to proactive denial prevention and revenue protection.
Sepsis remains one of the most frequently denied and contested diagnoses, creating costly revenue loss and compliance risks. In this webcast, Angela Comfort, DBA, MBA, RHIA, CDIP, CCS, CCS-P, provides practical, real-world strategies to align documentation with coding guidelines, reconcile Sepsis-2 and Sepsis-3 definitions, and apply compliant queries. You’ll learn how to identify and address documentation gaps, strengthen provider engagement, and defend diagnoses against payer scrutiny—equipping you to protect reimbursement, improve SOI/ROM capture, and reduce audit vulnerability in this high-risk area.
Only ICD10monitor delivers what you need: updates on must-know changes associated with the FY26 IPPS, including new ICD-10-CM/PCS codes, CCs/MCCs, and MS-DRGs, plus insights, analysis and answers to your questions from two of the country’s most respected subject matter experts.
Federal auditors are zeroing in on Inpatient Rehabilitation Facility (IRF) and hospital rehab unit services, with OIG and CERT audits leading to millions in penalties—often due to documentation and administrative errors, not quality of care. Join compliance expert Michael Calahan, PA, MBA, to learn the five clinical “pillars” of IRF-PPS admissions, key documentation requirements, and real-life case lessons to help protect your revenue.
During this essential RACmonitor webcast Michael Calahan, PA, MBA Certified Compliance Officer, will clarify the rules, dispel common misconceptions, and equip you with practical strategies to code, document, and bill high-risk split/shared, incident-to & critical care E/M services with confidence. Don’t let audit risks or revenue losses catch your organization off guard — learn exactly what federal auditors are looking for and how to ensure your documentation and reporting stand up to scrutiny.
Learn how to navigate the proposed elimination of the Inpatient-Only list. Gain strategies to assess admission status, avoid denials, protect compliance, and address impacts across Medicare and non-Medicare payors. Essential insights for hospitals.
RACmonitor is proud to welcome back Dr. Ronald Hirsch, one of his most requested webcasts. In this highly anticipated session, Dr. Hirsch will break down the complex Two Midnight Rule Medicare regulations, translating them into clear, actionable guidance. He’ll walk you through the basics of the rule, offer expert interpretation, and apply the rule to real-world clinical scenarios—so you leave with greater clarity, confidence, and the tools to ensure compliance.
Prepare for the 2025 CMS IPPS Final Rule with ICD10monitor’s IPPSPalooza! Click HERE to learn more
Get 15% OFF on all educational webcasts at ICD10monitor with code JULYFOURTH24 until July 4, 2024—start learning today!
CYBER WEEK IS HERE! Don’t miss your chance to get 20% off now until Dec. 2 with code CYBER24
