CMS Releases 2019 Proposed Rule: Top Things to Know

By Policy and Advocacy Brief posted 07-13-2018 15:58

On July 12, the Centers for Medicare & Medicaid Services (CMS) released the proposed rule for the 2019 Medicare Physician Fee Schedule, which also includes updates to the Quality Payment Program (QPP) and other Medicare Part B payment policies. The rule outlines a number of important changes of which urologists should be aware. 

Reduced E&M Documentation Burden

CMS is proposing a number of coding and payment changes that the agency says will reduce administrative burden and improve payment accuracy for Evaluation and Management (E&M) visits. Proposed changes include the following:

  • Giving providers greater flexibility for E&M documentation. Providers have the option of continuing to use current E&M guidelines, or to instead use medical decision-making or time to document E&M visits;
  • Revising documentation of history and exam to focus on what has changed since the last visit or on pertinent items that have not changed;
  • Allowing practitioners to review and approve – rather than re-enter – certain information entered in the medical record by others;
  • Creating single blended payment rates for new and established patients for office/outpatient E&M visit levels 2-5, and making additional accompanying payment changes intended to improve payment accuracy.
  • Creating a HCPCS add-on G code for visit complexity inherent to E&M associated with urology in addition to an E&M visit.

CMS is soliciting public comment on potentially eliminating a policy that prevents payment for same-day E&M visits by multiple practitioners in the same specialty within a group practice.

Conversion Factor Increase

Final 2018 Conversion Factor: $35.9996   

Proposed 2019 Conversion Factor: $36.0463   


Learn how the conversion factor affects your payment.


Increase in Allowable Charges for Urology

CMS estimates that the proposed Fee Schedule changes will result in a positive, 3 percent increase in allowable charges for urology (work RVU increase of 2 percent and PE increase of 1 percent).


Medicare Coverage and Payment of Communication Technology-Based Services

To support access to care using communication technology, CMS is proposing to:

  • Pay for virtual check-ins – brief, non-face-to-face check-ins conducted via communication technology to assess whether the patient’s condition requires an office visit;
  • Pay clinicians for evaluation of patient-submitted photos or recorded video;
  • Pay for interprofessional consultations conducted by telephone, Internet, or electronic health record; and
  • Expand Medicare-covered telehealth services to include prolonged preventive services.

Merit-based Incentive Payment System (MIPS) Changes

CMS is proposing the below changes in weights for the following MIPS categories: Quality, Promoting Interoperability (formerly Advancing Care Information), Improvement Activities, and Cost.


MIPS Performance Thresholds: To avoid penalties, MIPS-eligible clinicians must achieve a certain MIPS Final Score based on performance across all four MIPS categories, called the performance threshold. MIPS-eligible clinicians who exceed the performance threshold are eligible to receive upward payment adjustments. Additionally, MIPS eligible clinicians may quality for an additional payment adjustment if they exceed an exceptional performance threshold.

Proposed 2019 Threshold: 30 points (up from 15 points for 2018)
Proposed 2019 Exceptional Performance Threshold: 80 points (up from 70 points for 2018)

Requirements for Electronic Health Record (EHR) Technology Certification: 2019 MIPS-eligible physicians must use EHR systems that are certified to 2015 Certification Criteria.

Update: The AUA is in the process of reviewing the rule in its entirety, and has published a more detailed analysis, including conversion tables for common urology codes, on For more information or for questions, please contact the AUA at R&