2021 HOLDS SIGNIFICANT CHANGES TO E/M CODING GUIDELINES

New coding guidelines coming in 2021 show the most significant E/M guideline changes since 1997, changing the way physicians document office/outpatient codes 99202-99215 (descriptors attached in Figure 1). 

The American Medical Association advocated for the changes to ease the administrative burden on physician practices.

Changes to the logic include: 

• 99201 is eliminated and codes 99202-99215 are revised.
• Documentation includes a medically appropriate history and/or examination.
• Coding is now based on medical decision-making or total time on date of the encounter.  This includes both the face-to-face exam, counseling, and education of the patient directly and non-face-to-face time spent by the provider including:
  • reviewing any separately obtained history and/or test results,
  • counseling and education of family and/or caregivers,
  • ordering medicines, tests, or procedures,
  • consulting with other healthcare providers,
  • interpreting, reviewing, and sharing results with family/caregivers and
  • documenting information in the medical record.

New requirements for E/M codes in 2021

NEW PATIENT

*Qualified health care professional

CMS increased most of the Work RVU values for these CPT codes.  The new guidelines avoid the boiler plate “review of systems” not related to the patient’s condition.  They allow for more concise inquiry and documentation of clinically relevant information, specific to the case and the associated time spent on individual encounters. 

Purportedly, in many cases, this will reflect a higher level E/M code than previously billed which in turn will impact physician compensation.

Contrary to this, CMS has made these changes budget neutral, i.e. reducing the conversion factors for other physician services such as surgeons and proceduralists resulting in a potential reduction in reimbursement.

As always, until the final law is adopted, things can change.

For a more comprehensive definition of each code see Figure 1:  CPT-CODING-CHANGES.pdf