Proposed E&M Changes and The Effect on Podiatry

The Centers for Medicare and Medicaid Services (CMS) on July 27 released its plan to reduce paperwork and improve patient care.1 What CMS is proposing is to combine the evaluation and management (E&M) codes - that are currently CPT codes 99202 through 99205 for new patients, and CPT codes 99212 through 99215 for established patients, to a single payment level for a new patient and a single payment level for an established payment.

Podiatrists are being singled out from all other physicians and will be required to use new podiatry specific E&M codes developed by CMS, termed G codes. Documentation requirements would be the same as they currently are for level 2 codes (99202 or 99212 as applicable), but they will be reimbursed at a significantly lower rate than the standard E&M, even though they denote precisely the same E&M services that all other physicians provide. The idea supported by CMS that the reduction in the burden of paperwork will balance the revenue lost with lower reimbursements, will not be popular with podiatric physicians and an idea I do not agree with.

Under Medicare’s decree, podiatrists are physicians. However, they plan to differentiate podiatric payments with lower RVU’s than the payment to other providers. The plan infringes upon constitutional vernacular in the SS Act, which is extremely disturbing and downright unethical. Many physicians are quite concerned about this proposed rule by CMS.