The issue is the unknown. Tom hit it on the head when he said we won't know until implementation and each payor is likely to have different rules.
Again, it's an excuse to change the rules and how likely is it that they will change in our favor.
Sure, they could just apply it to 99215s but every payor will do it differently. some may want to go after 99212-3s.
Remember, they can request records without fees. That's included in most contracts. How they get the records is another matter. The cost of sending an auditor may keep them from going after "chump change" but then again.....
