A proposed restructuring of Centers for Medicare and Medicaid Services (CMS) Medicare Physician Fees may lead to an increase in required documentation and associated workload, according to an article published in the New England Journal of Medicine.

The proposed restructuring CMS physicians’ fees would begin in 2019. The initiative aimed to establish a single fee for level 2 through 5 office visits. This is in contrast to the current standard, which pays higher fees for higher visit levels. Under the new structure, the plan will pay $135 and $93 for new and established patients, respectively, regardless of the type of office visit. Add-on fees will be attached to services by primary care physicians and physicians of certain specialties.

According to the CMS, this new fee structure may help reduce the rising administrative burden often faced by physicians. While potentially helpful in this regard, the new initiative may worsen workforce-related deficiencies and pose risks to patients with complex needs, according to article authors Zirui Song, MD, PhD, and John D. Goodson, MD, of Harvard Medical School and Massachusetts General Hospital in Boston, Massachusetts. Physicians who care for patients with complex diseases will also experience a fee cut under this new payment program, particularly for level 4 and 5 visits, possibly resulting in physicians having to reduce their visit time and bring patients back more frequently to maintain their incomes.

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There is some debate that this fee structure change will worsen the current physician shortage in the United States. Ultimately, the policy may allow revenue disparities to persist “per unit of physician time between specialties that derive a larger share of revenue from procedures, tests, and imaging and specialties that depend on evaluation and management.” Another concern is the lack of certainty as to whether the policy would actually reduce administrative burdens, even in the CMS proposal to combine level 2 through 4 visits and keeping level 5 visits for complex patients.

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“We believe that CMS should be commended for this effort to reduce administrative burden,” wrote Drs Song and Goodson. “However, potential unintended consequences and persistent incentives or needs for documentation may blunt the impact of the proposed policy and render it undesirable for patients and providers.”


Song Z, Goodson JD. The CMS proposal to reform office-visit payments [published online August 15, 2018]. N Engl J Med. doi:10.1056/NEJMp1809742