The Centers for Medicare & Medicaid Services (CMS) physician fee schedule proposed rule has some new Part B specific codes for Podiatry Evaluation and Management (E/M) services as well as some modification to Teaching Physician Attestation Rules for 2019.

Changes to E/M Service Codes

CMS has also proposed the addition of two podiatry E/M codes specific to Medicare Part B patients who are receiving podiatric care. The reason for these codes are also targeting the reduction of administrative burdens on podiatrists while enabling them to providing services to their patients. CMS modeled these codes after the ophthalmologic evaluation and management codes. These codes are:

GPD0X: Podiatry services, medical exam, and evaluation with initiation of diagnostic and treatment program, new patient. Work and Practice Expense RVUs are 2.72.

GDP1X: Podiatry services, medical exam, and evaluation with initiation of diagnostic and treatment program, established patient. Work and Practice Expense RVUs are 1.81.

GPD0X has a proposed reimbursement for 2019 of $97.89. And GPD1X has a proposed reimbursement for 2019 of $65.14. This is pretty good news since the current 2018 reimbursement for 99203 is $78.12 and 99213 is $52.20.

CMS has assigned a reference time of 28 minutes for new patient GPD0X with a threshold of 15 minutes and a reference time for established patient GPD1X of 22 minutes with a threshold time of 12 minutes.

Changes to Teaching Physician Attestation Documentation

The CMS 2019 proposed rule has made changes to the Teaching Physician Attestation documentation. The rule creates exceptions to the full Teaching Physician Attestation in order to reduce the administrative burden on teaching physcians.

However, keep in mind that the exception would not apply to services that fall under the following:

• Hospital outpatient
• Ambulatory settings
• Renal dialysis services
• Psychiatric services

The proposed change is significant. For services that do not take place in the above 4 settings, the Teaching Attestation may be documented by the physician, the resident or the nurse. The requirement to participate in the review and direct the service will be eliminated. The extent of the review and the direction that was provided should be part of the documentation per the proposed rule. I am sure that there are many teaching physicians who will welcome this change because many charts that I currently audit, that are missing the teaching physician attestation, usually have a resident statement about the teaching physician review.