CMS’ proposed E&M changes: what’s next?

Last week the Advocacy Insider outlined the potential impact of the proposed collapse of the E&M codes, published in the July 27 Federal Register by the Centers for Medicare & Medicaid Services (CMS), from five codes to two. The codes most frequently used by allergists (levels 3 and 4) would be merged into one code, which will also include levels 2 and 5. The differential between new and established patients would be maintained, but consultant codes in the out-patient setting would be abolished. This would have minimal effect for allergists since we usually are involved in the active management of our patients, not acting just as a consultant sending the patient back to the referring doctor for management. The current proposal allows $135 for new patient visits and $93 for established visits. Allergists have been included in a list of specialties that would get an add-on complexity adjustment payment of $14.

CMS has launched numerous communication initiatives to educate providers on the changes including these E&M Coding Reform videos: IntroductionOffice Visits and Panel Discussion and a Physician Fee Schedule Proposed Rule: Understanding 3 Key Topics Listening Session on Wednesday, August 22 from 1:30 to 3 pm ET.

The AMA/Specialty Society RVS Update Committee (RUC) and the chairs of the CPT Editorial Panel have created an E&M Workgroup to develop a new E&M coding structure and consider relativity issues for these office visit services. The Advocacy Council will listen in on this call and will keep members appraised of proposed changes as the discussion continues.

We would like to hear your thoughts and concerns on these changes. Please email us at to express your opinion.

Advocacy Issue: 
Billing, Coding & Payments