AHIMA Comments on FY19 PFS Proposed Rule
AHIMA submitted comments to CMS on proposed revisions to the Physician Fee Schedule (PFS) proposed rule for calendar year 2019, as published in the July 27 issue of the Federal Register.
AHIMA commends CMS for its efforts to undertake a revision of evaluation and management (E/M) documentation requirements and agree that the current E/M documentation guidelines are outdated, overly complex, and not aligned with the current electronic environment. We recommend that CMS work with the American Medical Association's CPT Editorial Panel to comprehensively revise the E/M coding and documentation structure.
We also support a proposal to reduce redundancy in E/M visit documentation by allowing practitioners to focus their documentation of history and exam for established patients on what has changed since the last visit or on pertinent items that have not changed, and to no longer require practitioners to enter information in the medical record regarding the chief complaint and history if that information has already been entered by ancillary staff or the patient.
Finally, we commend a proposal to transition to a performance-based scoring methodology with fewer measures under the Promoting Interoperability performance category under MIPS and suggest that if CMS decides to implement new or revised Conditions of Participation/ Conditions for Coverage, and Requirements for Participation for Long-Term Care for interoperability and electronic exchange, a transition period or a delayed implementation date be instituted.