Unlike the SGR’s annual changes, MIPS adjusts physician payments based on performance. MIPS does not have an aggregate spending target, which is what previously created the need for annual congressional patches to prevent the mandated SGR cuts. MIPS started in 2017 at ±4 percent and increases to ±9 percent by 2022 (based on 2020 performance).

Future Changes to the Medicare 1995 and 1997 Documentation Guidelines

CMS has become concerned that the current documentation guidelines, particularly the burdensome aspects of history and physical exam documentation, have not kept pace with technology and has discussed moving to a set of guidelines that are more centered on medical decision making.

Ultimately, in the 2018 Physician Final Rule CMS stated: “Stakeholders have long maintained that both the 1995 and 1997 guidelines are administratively burdensome and outdated with respect to the practice of medicine, stating that they are too complex, ambiguous, and that they fail to distinguish meaningful differences among code levels. In general, we agree that there may be unnecessary burden with these guidelines and that they are potentially outdated, and believe this is especially true for the requirements for the history and the physical exam.”

Stay tuned, as CMS has forecasted making substantial revisions in the near future.

Dr. Granovsky is the president of Logix Health, an ED coding and billing company, and serves as the course director of ACEP’s coding and reimbursement courses as well as ACEP’s Reimbursement Committee. Mr. McKenzie is reimbursement director for ACEP