E/M Documentation Changes for Psychiatrists
E/M Documentation Changes for Psychiatrists
CMS had crafted a proposal that made a meaningful attempt to address the complexities of the current evaluation and management documentation guidelines and pared it with a significant proposal to simplify the payment structure. The documentation changes will go into effect in 2019 but the payment structure changes have been delayed until at least 2021. CMS finalized the following documentation changes, which can be implemented beginning in January 2019, so let’s explore E/M documentation changes for Psychiatrists:
- Physicians are no longer required to document the medical necessity for treating patients in their homes rather than in the office;
- When there is already relevant information in the record for established patients, physicians can choose to focus their documentation on what has changed since the last visit or pertinent items that have not changed. You no longer have to re-record elements of history and exam when there is documentation that those items have been reviewed and updated;
- CMS will allow physicians to indicate they have reviewed and verified information on the chief complaint and history that is already recorded in the record by ancillary staff or the patient; and
- CMS has removed potentially duplicative requirements for notations that may have already been included in the record by residents or other members of the team for E/M visits provided by a teaching physician.
For 2019, CMS has maintained separate fees for each of the five levels of E/M services used to describe care for new and established patients in the office/outpatient setting. Beginning in 2021, CMS plans to implement a blended payment for both new and established office/outpatient E/M visits, paying the same amount for levels 2 through 4. Level 5 will be paid at a higher amount to account for work in providing care to the most complex patients.
CMS has also created new add-on codes, including one that can be used by psychiatrists and others to account for visit complexity associated with an E/M service. A new “extended visit” code will also be put in place to account for additional resources required when a level 2, 3, or 4 services requires additional time. A chart on the CMS website provides the details of the planned 2021 E/M code structure.
In addition to the simplification of the payment amounts, CMS proposes to permit physicians the option of documenting office/outpatient E/M visits using medical decision making, time, or the existing 1995 or 1997 E/M documentation guidelines. Time would be an option whether or not the time was spent on counseling and/or coordination of care. Again, these changes are set to begin in 2021, and CMS remains open to feedback on these items.
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