I finally wrote my comments regarding the proposed changes to E&M coding, figured I'd share. This proposed change could destroy #Geriatrics and #HPM. Here are my comments:

I agree that the existing CPT coding system is inadequate. However, lumping together four E&M codes into one will have a serious unintended consequence. It will lead to clinicians spending less time with patients. When it comes to the care of older adults, this is profoundly disturbing. The simpler solution would be to pay physicians for the time that they take caring for patients. The risk of abuse of this methodology is very limited, especially because the patients themselves become the auditors! The greatest negative impact of this proposal will be its effect on the care of patients with complex problems, and frail older adults are the most obvious population that could be harmed by this change.

I am a geriatrician and have not only cared for frail older adults for nearly thirty years, but I have also been an entrepreneur. I co-founded and built one of the largest primary care geriatrics private practices in the country. I have managed countless clinicians during my career. I have been a student of the CPT coding system and all that is wrong with it. I appreciate the sentiment that the present system doesn't work properly. However, some of us have figured out how to utilize the existing system by taking advantage of "time-based coding." This type of coding allows the clinician to avoid the extra paperwork and nonsensical "bullet-point" documentation that doesn't help to improve care. By lumping the four codes together, you will take away the ability of dedicated clinicians to spend the necessary time with patients in order to deliver comprehensive complex care.

We must encourage clinicians to focus on delivering person-centered care. Quality geriatrics care often requires the need to spend time with highly complex individuals. It is critical that clinicians not feel limited in their ability to deliver this important care. Under the new system, clinicians will be reimbursed more for seeing a higher volume of patients. This runs counter to our Hippocratic oath. We need the ability to spend whatever time is necessary to care for patients. 

Please strongly consider allowing physicians to bill based purely on the time they spend with patients. The natural auditors of such a system are the very patients we are trained to serve. The ability to abuse such a system is limited to the total hours in a day, and obviously, less than that to the discerning eye. The broad brush response of combining codes is a misguided attempt to improve a broken system. Please don't make this mistake, it frightens me to no end.