Quick Hits

AAO backs CMS “note bloat” fixes

The change, supported by 150 other medical groups, is one of several proposed under “Patients Over Paperwork” initiative.

The AAO, along with approximately 150 other medical groups, co-signed a statement supporting parts of the Centers for Medicare and Medicaid Services’ (CMS) “Patients Over Paperwork” initiative to reduce administrative burden on physicians.

However, the statement also expressed skepticism of a related proposal to change payment rates, resulting in less money for physicians treating more complex ailments.

The “Patients Over Paperwork” initiative is part of CMS’ proposed changes for the 2019 Medicare physician payment rule.


The proposed new CMS rules supported by the medical groups simplified requirements associated with Evaluation and Management (E/M) services.

“Excessive E/M documentation requirements do not just take time away from patient care; they also make it more difficult to locate medical information in patients’ records that is necessary to provide high quality care,” the groups wrote in their statement, addressed to CMS administrator Seema Verma.

“Physicians and other health-care professionals are extremely frustrated by ‘note bloat,’ with pages and pages of redundant information that makes it difficult to quickly find important information about the patient’s present illness or most recent test results. Several of the documentation policy changes included in the proposed rule would go a long way toward alleviating this problem and the undersigned organizations urge immediate adoption.”

Among these proposals are: Changing required documentation of a patient’s history to focus only on the time period between the current visit and the last; eliminating a requirement that physicians must re-document patient information previously recorded by staff or by the patient; and removing the need to justify a home visit instead of an office visit.


Cathy G. Cohen, AAO vice president for government affairs, voiced her group’s support for these changes. “The Academy is a vocal proponent of decreasing these and other administrative burdens to ensure that our patients can receive the care they require.”

For this issue, “there is a negative effect on nearly all medical specialty groups,” hence the need for the group statement, adds Ms. Cohen.

Kevin Corcoran, president of Corcoran Consulting Group, states that ophthalmologists are somewhat insulated from the proposed rule changes to E/M documentation and payment, as they use eye codes about twice as often as E/M codes, and the CMS’ proposed CY 2019 Medicare Physician Fee Schedule makes no significant changes to eye codes 92004, 92014, 92002 and 92012.

Ms. Cohen also notes that ophthalmology makes up only “a small percentage” of all E/M code utilization, but some AAO members employed in large groups or medical centers are required to use E/M codes for consistency with other departments. These ophthalmologists will be affected the most by these changes, she says.


The joint statement, however, opposes a proposal to collapse payment rates for E/M office visits down to two different levels, as opposed to five (see Tables 1 and 2).

Table 1. Current physician fee schedule payments for E/M visits
Level Payments for established patient Payments for new patients
992x1 $22 $45
992x2 $45 $76
992x3 $74 $110
992x4 $109 $167
992x5 $148 $211
Table 2. Proposed new physician fee schedule payments for E/M visits
Level Payments for established patient Payments for new patients
992x1 $24 $44
992x2-992x5 $93 $135

As a primary result of this change, physicians who treat sicker patients with more complex conditions would only get paid the same as physicians “treating a common cold or other lesser ailments,” according to Ms. Cohen.

Physicians who disproportionately use higher-level E/M codes, such as neuro-ophthalmologists, would fall into this category and would be the main opponents of this new proposal, says Mr. Corcoran.

The statement issued by the medical groups supports the American Medical Association’s creation of a physician and health professional workgroup to help find solutions for E/M coding and payment issues; the workgroup would provide its findings to CMS in time to be implemented in the 2020 Medicare Physician Fee Schedule.

For the statement’s full text, visit .

For more information on the CMS’ proposed new rules, visit . OM


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