Skip to main content Back to Top

Hospitals and Health Systems Submit Joint Comment Letter to the Centers for Medicare & Medicaid Services Requesting Revision of 2020 E/M Policy Change

Centers for Medicare and Medicaid

September 13, 2021

The undersigned hospitals and health systems urge the Centers for Medicare & Medicaid Services (CMS) to ensure that providers can fully engage all members of the healthcare team, including pharmacists, in patient care. Specifically, we urge CMS to reverse a 2020 policy change limiting physicians to billing only the lowest-level evaluation and management (E/M) code for pharmacist-provided incident-to services, regardless of the duration and complexity of the E/M services provided.1 This policy shift undermines health system care models that leverage clinical pharmacists to support our physicians and care teams, thereby threatening patient access to critical services, including comprehensive medication management.

In our organizations, pharmacists provide team-based clinical services in both the inpatient and outpatient setting. Clinical pharmacists collaborate with our physicians, nurses, and other healthcare professionals to provide safe and effective medication use and improve patient health outcomes while reducing workload burdens on physicians and other clinical staff.2,3 They educate patients and caregivers about their medications, monitor drug therapy, and coordinate communication between patients, insurers, and interdisciplinary specialty providers.

Drug therapy is involved in 76% of physician office visits and is the sole treatment for many acute and chronic conditions. Problems associated with medication use, such as non-adherence, polypharmacy, errors and adverse events, result in 500,000 emergency room visits and 100,000 hospitalizations yearly, costing the health system over an estimated five billion dollars.4 Pharmacists’ management of medication therapy has been shown to improve transitions of care and reduce hospital readmissions.5,6

Unfortunately, the CMS E/M policy change significantly undervalues the critical role of our clinical pharmacists in providing medication management services to Medicare beneficiaries. The CMS E/M policy change is fundamentally at odds with efforts to implement care models that include clinical pharmacists. Many commercial payers as well as states consider pharmacists to be qualified health professionals (QHPs) whose services can be billed incident-to a physician using the higher-level E/M codes. The American Medical Association (AMA) CPT Code Book also recognizes pharmacists as QHPs eligible to “report services.” Indeed, CMS issues National Provider Identifier numbers to pharmacists for just this reason. Pharmacists and pharmacies can bill using their NPI number for immunizations and pharmacists can bill Diabetic Self-Management Training (DSMT) and Medicare Diabetes Prevention Program services if they meet the requirements for these services.

CMS’ policy preventing health systems from billing for pharmacist services provided incident to a physician service serves as an unnecessary barrier to broader adoption of innovative team-based care that enhances quality care for our patients. Adverse drug events contribute to an estimated 275,689 deaths per year and cost $528.4 billion annually. 5 Medication management provided by pharmacists, as part of our care teams, is an important tool to improve these outcomes.

Reversing the 2020 E/M policy change and allowing health systems to bill for the services provided by the clinical pharmacists on their care teams incident to a physician would help ensure our patients have access to the best possible medication management. Barring a full reversal of the policy change, we urge CMS to adopt either a pharmacist modifier for existing E/M codes or a new pharmacist-specific code set that corresponds to the higher-level E/M codes and accounts for the duration and complexity of pharmacist-provided incident-to services. We look forward to working with you to implement regulations that allow health systems to fully integrate clinical pharmacists on our care teams.


Advocate Aurora Health
Allina Health
Atrium Health - Charlotte Region (North Carolina)
Atrium Health - Wake Forest Baptist
Atrium Health - Floyd Health System
Atrium Health - Navicent (Georgia)
Avera Health
Baptist Health
Baptist Health South Florida
Bon Secours Mercy Health
Cedars-Sinai Medical Center
Centura Health
Cleveland Clinic Health System
CommonSpirit Health
Cone Health
Deaconess Health System
Duke University Health System
Ephraim McDowell Health
Geisinger Health
Harris Health System
Hartford Healthcare
Huntsville Hospital/HH Health System
Inova Health System
Jackson Health System
Lee Health
Legacy Health
Loma Linda University Health
Mass General Brigham
Memorial HealthCare System
MemorialCare Long Beach Medical Center/Miller Children's and Women's Hospital
Methodist Health System
Northwestern Medicine
Norton Healthcare, Inc.
Novant Health New Hanover Regional Medical Center
Ohio Health
Oschner Health
OSF Healthcare
Rochester Regional Health
Sanford Health
Santa Clara Valley Medical Center
SCL Health
The Ohio State University Wexner Medical Center
UNC Eshelman School of Pharmacy
UNC Health
UnityPoint Health
University Hospitals of Cleveland
University of California Health
University of Chicago Medicine
University of Maryland Medical System
University of Michigan Health
University of Missouri Health Care
University of Rochester Medical Center
University of Tennessee Medical Center
Vidant Health System


 [1] Centers for Medicare & Medicaid Services, Physician Fee Schedule CY 2021 Final Rule, 85 Fed. Reg. 84592-3 (Dec. 28, 2020), available at (Limiting physicians supervising pharmacist-provided incident-to services to billing code 99211 for those services, despite the fact that many of the services provided by pharmacists meet the complexity and duration criteria set forth for code 99212-14).

[2] McFarland, MS, Nelson J, Ourth H, Groppi J and Morreale A. Optimizing the primary care clinical pharmacy specialist: Increasing patient access and quality of care within the Veterans Health Administration. J Am Coll Clin Pharm. 2020;3:494-500.

[3] Funk, K., Pestka, D., McClurg, M., Carroll, J., Sorensen, T. Primary Care Providers Believe That Comprehensive Medication Management Improves Their Work-Life. Journal of American Board of Family Medicine. 2019; 32(4): 462-473. doi: 10.3122/ jabfm.2019.04.180376

[4] Budnitz DS, Pollock DA, Weidenbach KN, et al. National surveillance of emergency department visits for outpatient adverse drug events. JAMA. 2006;296:1858-1866; See also Watanabe JH, McInnis T, Hirsch JD. Cost of Prescription Drug–Related Morbidity and Mortality. Annals of Pharmacotherapy 2018, Vol. 52(9) 829 –837.

[5] Ni, W., Colayco, D., Hashimoto, J.,Komoto, K., Gowda, C., Wearda, B., McCombs, J. Budget Impact Analysis of a PharmacistProvided Transition of Care Program. Journal of Managed Care & Specialty Pharmacy. Feb 2018.

[6] Budlong, H, Brummel, A, Rhodes, A, Nici, H. Impact of Comprehensive Medication Management on Hospital Readmission Rates. Population Health Management 2018. 21(5): 395-400.