The Alliance submitted comments to CMS' proposed CY 2019 Physician Fee Schedule supporting specific provisions to ease paperwork/documentation burdens, including:

• Changing the required documentation of the patient’s history to focus only on the interval history since the previous visit;
• Eliminating the requirement for physicians to re-document information that has already been documented in the patient’s record by practice staff or by the patient
• Allowing physicians to choose between current documentation guidelines, documenting by time only, or documenting by medical decision making only
• Removing the need to justify providing a home visit instead of an office visit. However, the Alliance also used its comments to voice its strong opposition to the consolidation of Evaluation and Management codes and the corresponding reduction in payment for E/M services for those that provide the most complex care. The Alliance submitted a series of examples of unintended consequences that the proposal would create and urged CMS not to move forward with that provision.

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