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August 15, 2018

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IDSA Takes Action on Potentially Harmful Proposed E/M Code Changes

The Centers for Medicare & Medicaid Services (CMS) has proposed drastic changes to payment rates for outpatient Evaluation & Management (E/M) codes (both new and existing Medicare patients) that would result in an approximate 40 percent reduction for a level 5 E/M visit (see tables below).

Should the proposal be finalized, it is very likely that commercial payers will follow suit, and inpatient E/M codes may be next. This issue potentially has dire consequences for patient care, ID physicians’ compensation, and the future of our specialty.

IDSA is formulating a response to CMS to convey our strong opposition to the proposed changes and carefully characterize the devastating impact, should CMS finalize the proposed payment rates.  The public comment period for this proposal will end September 10. We need as many voices as possible to help stop this proposal, so we urge you to share your concerns in the following ways:

  1. Comment directly to CMS. It is important that you personalize your comments to CMS, so we have not prepared a templated message for this communication. Rather, we ask that you take time to characterize the following points in your comments, which can be submitted here:
    • the complexity of the cases you see every day
    • the negative impact a reduction in payment for outpatient complex cognitive care will have on your patients and you personally
    • the devastating consequences the proposed changes would have on the future of our specialty.
  2. Contact your members of Congress. Since volume is key when contacting legislators, click here to send IDSA’s template letter to your congressional representatives. 

IDSA Board Member Dan McQuillen, MD, FIDSA, recently met with CMS Administrator Seema Verma along with other societies, including the American Gastroenterological Association, American Geriatric Society, American Medical Association, American College of Physicians, American Psychiatric Association, and the American Society of Nephrology.  The meeting was a listening session that allowed societies to provide feedback and seek clarity on some of the proposed changes. CMS indicated an openness to constructive criticism as well as proposals for better solutions to the problem they intend to address: administrativeburden placed on physicians who perform outpatient E/M services. For more information on this meeting, please see Dr. McQuillen’s post in MyIDSA.

We will continue to provide updates in IDSA News, MyIDSA and other communications. 

Table 1: Preliminary Comparison of Payment Rates for Office Visits for New Patients 

HCPCS Code

CY2018 Non-facility Payment Rate

CY2018 Non-facility Payment Rate Under the Proposed Methodology

99201

$45

$44

99202

$76

$135

99203

$110

99204

$167

99205

$211

 

Table 2: Preliminary Comparison of Payment Rates for Office Existing Patients

HCPCS Code

CY2018 Non-facility Payment Rate

CY2018 Non-facility Payment Rate Under the Proposed Methodology

99211

$22

$24

99212

$45

$93

99213

$74

99214

$109

99215

$148

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