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The Honorable Seema Verma
Administrator Centers for Medicare & Medicaid Services
U.S. Department of Health and Human Services
Hubert H. Humphrey Building, Room 445–G
200 Independence Avenue, SW
Washington, DC 20201

Re: Medicare Physician Fee Schedule for CY 2019 (CMS-1693-P)

Dear Administrator Verma:

The undersigned organizations representing physicians and other health professionals welcome and strongly support the Centers for Medicare & Medicaid Services’ (CMS) “Patients Over Paperwork” initiative. We appreciate your outreach to our community and are solidly behind your goal of reducing administrative burdens for physicians and other health care professionals so that they can devote more time to patient care. The proposals included in the 2019 Medicare physician payment rule demonstrate that you listened to our members’ concerns about the significant administrative burdens due to the documentation requirements associated with Evaluation and Management (E/M) services. We are grateful for your efforts to simplify these requirements and reduce their associated red tape.

Excessive E/M documentation requirements do not just take time away from patient care; they also make it more difficult to locate medical information in patients’ records that is necessary to provide high quality care. Physicians and other health care professionals are extremely frustrated by “note bloat,” with pages and pages of redundant information that makes it difficult to quickly find important information about the patient’s present illness or most recent test results. Several of the documentation policy changes included in the proposed rule would go a long way toward alleviating this problem and the undersigned organizations urge immediate adoption:

1. Changing the required documentation of the patient’s history to focus only on the interval history since the previous visit;
2. 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; and
3. Removing the need to justify providing a home visit instead of an office visit.

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