Big E/M Changes Coming In 2021

Major changes are coming to office and outpatient evaluation and management (E/M) coding that will take effect January 1, 2021. These changes only affect CPT codes 99201-99205 and 99211-99215.

CPT 99201 (Office or other outpatient visit for the evaluation and management of a new patient) will no longer exist as of January 1, 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, one can use time if counseling and coordinating dominate the encounter. Starting January 1, 2021, the performance of a history and/or exam will still be necessary in order to report an office/outpatient E/M service, but they will no longer play a role in office/outpatient E/M code selection. Instead, one will select the code based upon either the level of medical decision making (MDM) only or total time only.

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. 

The current E/M documentation guidelines make it difficult for those physicians who specialize in one area of the body to reach the necessary thresholds of CPT 99204, 99205 and 99215. This change will eliminate that difficulty.

Conclusion

With these changes only applying to office and outpatient E/M services, there will be one set of guidelines for coding office/outpatient E/M services and a different set of guidelines for all other E/M services. Fortunately, we have well over one year to digest these changes, provide the appropriate training and be ready for January 1, 2021.

Dr. Lehrman operates Lehrman Consulting, LLC, is a consultant to the APMA Health Policy and Practice Department, serves as an expert panelist on Codingline, and is a Certified Professional Coder. Follow him on Twitter @DrLehrman

Reference

1. American Medical Association. CPT® Editorial Summary of Panel Actions February 2019. Available at: https://www.ama-assn.org/system/files/2019-03/february-2019-summary-panel-actions_0.pdf . Accessed April 23, 2019.