News Alert: E&M Changes Coming Soon

E&M code changes are expected to become effective in 2021.

The American Medical Association (AMA) released on March 8 the summary of panel actions that took place at the February 2019 CPT® panel meeting. The exact wording is not considered to be finalized until just prior to the release of the following year’s code set.  Furthermore, more specific information than what is shared through panel actions may be released prior to publication of the new code set. 

With those stipulations, there were panel actions that will have a significant impact on Office and Outpatient Evaluation and Management (E&M) coding that will take effect Jan. 1, 2021.

Deletion of CPT 99201 
The panel voted to delete CPT 99201(Office or other outpatient visits for the evaluation and management of a new patient).  This code saw low utilization and will no longer exist as of Jan. 1, 2021.  It is important to note that this does not apply to only a certain payer or a certain part of the country, but rather this code will be deleted from CPT.

Change To Certain Code Selection Criteria
The criteria that is used to determine the level of an office or outpatient E&M service will change dramatically in 2021.  Currently, the instruction is to use the thresholds of all three E&M key elements of history, exam, and decision making to determine the level of a new office/outpatient encounter and to use two out of the three key elements to determine the level of an established office / outpatient encounter.  Alternatively, time can be used if counseling and coordinating dominate the encounter.  Starting Jan. 1, 2021, the key elements of history and exam will no longer play a role in office / outpatient E&M code selection.  The performance of a history and/or exam will be necessary in order to report an office/outpatient E&M service, but they will not play a role in code selection.  Instead, the code will be selected based upon either the level of medical decision making (MDM) or total time.

Change in The Definition of Time
We are accustomed to quantifying face-to-face time and time spent counseling and coordinating.  However, starting in 2021, the time values associated with each office/outpatient E&M code will indicate the total time spent on the day of the encounter.  We will no longer need to determine how much of that time was spent in counseling and coordinating.  There will be changes in the time values associated with each office/outpatient E&M code.

Change To Office / Outpatient MDM Elements
There will be slight changes to the titles of the three elements that are used to determine the level of MDM.  “Number of Diagnoses or Management Options” will be changed to “Number and Complexity of Problems Addressed.”  In addition, “Amount and/or Complexity of Data to be Reviewed” will change to “Amount and/or Complexity of Data to be Reviewed and Analyzed.”  Finally, “Risk of Complications and/or Morbidity or Mortality” will change to “Risk of Complications and/or Morbidity or Mortality of Patient Management.”

Other E&M Services Affected?
These changes will only apply to office and outpatient E&M services (CPT 99202 – 99215).  Guidelines for hospital observation, hospital inpatient, consultations, Emergency Department, nursing facility, domiciliary, rest home, custodial care, and home E&M services will not change.  Therefore, there will be one set of guidelines for determining the appropriate code for office/outpatient E&M services and a different set of guidelines for all other E&M services.

Conclusion
While these are the publicly reported panel actions, they should not be considered final until the 2021 CPT book is published.  Fortunately, we have well over one year to digest these changes, provide the appropriate training, and be ready for Jan. 1, 2021.

Programming Note:
Listen to Dr. Lehrman report this story live during Talk Ten Tuesdays this Tuesday, March 19, 10-10:30 a.m. EDT.

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