Redocumentation of Evaluation and Management Services No Longer Required for CNMs


On Friday, November 1, 2019, the Centers for Medicare & Medicaid Services (CMS) released its CY 2020 final rule for the Medicare Physician Fee Schedule. The physician fee schedule dictates Medicare payment rates and policies under Part B, while the Quality Payment Program (QPP) implements two key value-based payment programs: The Merit-Based Incentive Payment System (MIPS) and Alternative Payment Models (APMs). Of significance to ACNM’s members are the changes in Medicare’s approach to evaluation and management (E/M) services. Slated to take effect in CY 2021, CMS has finalized modifications to the current documentation policy so that CNMs and other Advanced Practice Registered Nurses (APRNs) who furnish and bill for their professional services, can review and verify (sign and date), rather than redocumenting, notes made in a patient’s medical record by other physicians, residents, nurses, students or other members of the medical team. This change is applicable to all Medicare-covered services paid under Medicare’s Physician Fee Schedule.

This modification is due in part to the agency’s “Patients Over Paperwork” initiative which has focused on streamlining processes and removing overly burdensome administrative requirements within the Medicare program. The welcomed change is also a result of the advocacy efforts of the ACNM who continue to work alongside the American Nurses Association and other organizations representing APRNs to address the myriad of arbitrary barriers that exist within the Medicare program that unduly impact a midwife’s ability to practice to full extent of their scope.

ACNM applauds the change as it puts patients first by enabling CNMs to spend more time with their patients. The change will also result in reduced administrative burdens of teaching CNMs enabling them to spend more time teaching and precepting students and spending less time outside of patient care delivery completing their documentation.