2019 Physician Fee Schedule: Big Changes Ahead

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.


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.:


Final Policy, Payment, and Quality Provisions Changes to the Medicare Physician Fee Schedule for Calendar Year 2019:


Fact sheet on the CY 2019 Quality Payment Program final rule:


Program Note:

Listen to Dr. Lehrman report on this topic today on Talk Ten Tuesdays, 10 a.m. ET.

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Jeffrey D. Lehrman, DPM, FASPS, MAPWCA, CPC

Dr. Lehrman is a Certified Professional Coder, Certified Professional Medical Auditor and a podiatrist practicing in Fort Collins, CO. He operates Lehrman Consulting, LLC, which provides consultation services regarding coding, compliance and documentation. Dr. Lehrman serves as a staff liaison at the AMA CPT® Editorial Panel meetings, where CPT codes are created, edited and deleted.

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