CMS Backs Away from E/M Coding Changes after AMGA’s Objection
Association Continues to Oppose High MIPS Exclusion Thresholds

Alexandria, VA – AMGA today stated that it is encouraged that Centers for Medicare & Medicaid Services (CMS) opted not to finalize a proposed change to Evaluation and Management (E/M) office visit codes in the new physician fee schedule rule. However, the association voiced concerns regarding high exclusion thresholds in the Merit-Based Incentive Payment System (MIPS).

Under the rule that CMS finalized today, the current E/M codes will be replaced with a new, single blended payment rate for E/M Level 2 through 4 visits. This change will be effective in 2021 and marks a change from CMS’ earlier proposal, which would have collapsed Level 2 through 5 codes into a single payment by 2019. AMGA earlier voiced opposition to the original proposal, which would have caused a disruption in physician work flow and referral patterns, and will evaluate this new change carefully.

CMS also is implementing a number of documentation requirement changes that are intended to reduce the burden on providers. Originally, CMS’ proposal linked documentation requirements with the proposed E/M coding and payment changes. By moving forward with its documentation changes in 2019 while delaying the payment and coding changes, CMS acknowledged AMGA’s objection to pairing paperwork reforms with significant coding and payment reforms.

“AMGA members were very concerned that CMS was moving too aggressively in its plan to streamline the payment and coding for E/M office visits, particularly those providers who treat a large number of complex patients,” said AMGA President and CEO Jerry Penso, M.D., M.B.A. “Maintaining the code for the most complex patient visits somewhat alleviates that concern.”

Penso added that AMGA supports CMS’ decision to finalize a number of its proposed documentation requirements. “Additional flexibility in how care is documented allows providers to focus on their patients, not their computers,” Penso said.

High Exclusion Continues Problems with MIPS

CMS also finalized high MIPS exclusion thresholds, which while intended to transition providers into the program, instead serve to undermine the efforts of high-performing providers already participating in the program.

“We’re puzzled by CMS’ decision to continue to exempt providers from MIPS. On one hand, CMS is speeding toward value-based care by accelerating the transition to risk-bearing models in the Medicare Shared Savings Program,” Penso said. “At the same time, CMS is excusing other providers from having to consider moving toward value at all. It’s disappointing and seems to be at odds with CMS’ stated goals regarding value-based payment.”


About AMGA
AMGA is a trade association leading the transformation of health care in America. Representing multispecialty medical groups and integrated systems of care, we advocate, educate, innovate, and empower our members to deliver the next level of high performance health. AMGA is the national voice promoting awareness of our members’ recognized excellence in the delivery of coordinated, high quality, high-value care. More than 175,000 physicians practice in our member organizations, delivering care to one in three Americans.


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