On Dec. 8, 2017, members of the Cognitive Care Alliance (CCA)—of which the ACR is a leading member—met with members of Congress on the Hill and representatives from the Centers for Medicare and Medicaid Services (CMS) to discuss ongoing concerns about the inadequacy of existing evaluation and management (E/M) codes to properly remunerate cognitive services provided by rheumatologists.
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The meeting followed on the heels of a final rule issued by the CMS on Nov. 2, 2017, on policy, payment and quality provisions in the Medicare Physician Fee Schedule for 2018.1 In the final rule, no substantial changes were made to existing E/M codes for cognitive services, but the CMS did acknowledge that current guidelines on E/M codes may be outdated and in need of revision. The CMS invited stakeholders to collaborate with it on implementing needed changes for future rulemaking.
In the December meeting, the ACR and other members of the CCA urged the CMS to conduct a study of cognitive E/M work to restore accuracy and precision to the Physician Fee Schedule. The results of the study would be used to develop new service codes, more appropriately value cognitive work and develop new documentation requirements to reduce administrative burdens and better utilize existing electronic health record (EHR) technology.
According to Tim Laing, MD, former chair of the ACR Government Affairs Committee and the ACR’s physician representative to the CCA, who attended the meeting, the special advisors to the CMS Administrator agreed to study the information that the CCA provided on the need for revamping of the E/M codes for cognitive services.
“We believe current payment methodologies cannot capture the intensity and complexity of cognitive care services, and we impressed on them [the CMS advisors] our strong recommendation that CMS commission a comprehensive study of these services,” says Dr. Laing.
The overall changes to the E/M codes for cognitive services that the ACR would like the CMS to make were detailed in an August 2017 response the ACR sent to the Committee on Ways and Means and Subcommittee on Health Regarding Statutory and Regulatory Burdens on Optimized Efficiency and Patient Care. In the submission to the subcommittee, the ACR highlighted the failure of the existing E/M codes to adequately describe the work demanded by cognitive medical practice, and also emphasized that the codes have not maintained their relative valuation regarding other physician services with Medicare’s Physician Fee Schedule.