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Recommendations for the CMS 2019 RVU Proposal for E&M

As you may have heard, the CMS 2019 Relative Value Unit (RVU) weighting for E&M visits is proposed to effectively shift to a two-level system, with level 1 visits receiving a minimal weighting and levels 2-5 being weighted equally. CMS has stated that this change is intended to reduce the back-office burden of office visits, and that overall total average reimbursement for these visits should remain the same. However, depending on past coding patterns for any given provider, this may have a material impact to Work Relative Value Unit (wRVU) based compensation arrangements.

The final rule for 2019 is typically issued in late October or early November, so we should know soon whether or not this proposal will become reality on January 1.

If this is the case, we’re recommending an immediate review of all wRVU-based compensation arrangements. Depending on the exact terms of these agreements, this change may have a material effect on the total payments which not only poses a financial risk but also may have fair market value implications.

Click here to view the 2019 proposed rule with the codes in question highlighted in yellow.

Please let us know if you have any time to discuss this prior to the finalization of the rule. If finalized, we propose the following:

  • Review of all wRVU-based compensation arrangements;
  • Determination of the potential financial impact of the 2019 RVU assignments and reimbursement; and
  • Evaluation of revised compensation arrangements in order to: Adjust payment rates to be consistent with the original intent of the agreements and support compliance with federal regulations and guidance regarding fair market value and commercial reasonableness.

Please feel free to reach out at any time if you have any questions or concerns.

Best regards.

Jeff Moffatt, Senior Manager

Tax Reform Resource Center

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