Skip to Main Content

2019 Coding Update

Join AUGS' Efforts to Oppose Center for Medicare and Medicaid Services (CMS) Proposal to Reduce Office Visit Reimbursement to Physicians in 2019

Download Comment Toolkit

The recent 2019 Medicare Physician Fee Schedule Rule released on July 12, 2018, contains a proposed revamping of the E/M visit coding with the intent of decreasing documentation requirements and adding efficiency to the providers work flow in the clinic/office. Though physicians universally applaud the desire for simplification, there are concerns regarding the unintended consequences of the restructured reimbursement system as proposed and some of the proposals regarding documentation are still confusing.  It is also unclear how any of these would be implemented by private insurance plans.  

The current proposal would not change the actual CPT codes reported by the physician however, the reimbursement for levels 2-5 would be paid at the same amount. CPT codes 99202-99205 would reimburse $134 and CPT codes 99212-99215 would reimburse $92.  CMS is proposing two G-codes for physicians that treat certain conditions, gynecology being one, to also bill that would pay an additional $14.

CMS is also proposing that any other procedure performed concomitantly on the same day of service would undergo a 50% reduction of the lesser service fee. These additional procedures would typically be reported with the 25-modifier for the separate and identifiable service.  Click here for a summary of the proposal.

Superficial evaluation of the proposal notes an improvement in reimbursement for providers typically coding lower levels of service and not performing any other procedures on the same day. Alternatively, the more complex patients who require higher levels of care would see a decrease in reimbursement and still incur the 50% multi-procedure reduction.  

AUGS staff and Coding Committee Physicians are working diligently to obtain actual “real-life” data reflective of the practice of our specialty and create proformas to analyze the effects of the proposal for Society Members. AUGS is also working with the AMA, ACOG, ACS and other sister societies to present a unified, data-driven voice to assist CMS with their desire for simplified E/M reporting.  We are participating in an AMA lead workgroup regarding the future of the Office visit codes.  We are evaluating sign on letters and AUGS is preparing its own comment letter to CMS by the September 10th deadline.

AUGS is also providing its members with a “Comment Toolkit,” to send your own individual comment to CMS during the initial comment period ending on September 10, 2018. Please take the time to write a comment letter to CMS. If you need help or more information, please contact AUGS staff at Any additional comments are also welcome as AUGS works to represent YOU in this endeavor. 

For reference, below is a table outlining CMS’ proposed payment rates for 2019 versus 2018:

CPT Code

New Office Visits

CY 2018

Non-Facility Payment Rate

CY 2019 Proposed

Non-Facility Payment Rate















CPT Code

Est. Office Visits

CY 2018

Non-Facility Payment Rate

CY 2019 Proposed

Non-Facility Payment Rate