Professional Documents
Culture Documents
1997-2010
1992 1995 July 1, 2022
Refining of
AMA created CMS Published Guidelines (2000 AMA finalized 2023
E/M codes Calculations proposal rejected) E/M revisions
Nov. 1, 2019
1994 1997
CMS finalized 2021 office
CMS Revision of and other outpatient E/M
Marshfield Calculations
Clinic Beta revisions (implementation
Tool 1/1/2021)
Deleted & Revision Codes
Evaluation and Management Categories for face-to-face encounter with the patient and/or
family:
• Office or Other Outpatient Services
• For 99211, the face-to-face services may be performed by clinical staff
• Hospital Inpatient and Observation Care Services
• Consultations
• Emergency Department Services
• For 99281, the face-to-face services may be performed by clinical staff
• Nursing Facility Services
• Home or Residence Services
• Prolonged Service With or Without Direct Patient Contact on the Date of an Evaluation
and Management Service
Deleted & Revision Codes
Deleted Additions/Revisions
99217 - OBS Discharge 99238, 99239
99218 - 99220 - Initial OBS 99221 - 99223
99224 - 99226: Subsequent OBS 99231 - 99233
99241 & 99251: Outpatient & Inpat Consultations 99242
99318: Nursing Facility Service 99307 - 99310
99324 - 99328: Domiciliary, rest Home, Custodial New Patient 99341, 99342, 99334 , 99345
99334 - 99337: Domiciliary, rest Home, Custodial Est Patient 99347 - 99350
99339 - 99340: Domicilliary, rest Home, Home Care CPO 99437, 99491, 99424, 99425
99343: Home or Residence Services 99341 - 99345
99356 - 99357: Prolonged Service Inpatient pr OBS 993X0
New & Established Patient
New Vs Established
Covering or “on-
call” providers
should select the
relationship code
the unavailable
provider would
have used.
Initial vs Subsequent
MDM & Time
Coders and providers are required to choose E/M visit levels based on either:
Medical Decision Making (using the new office/OP revisions MDM table) or
Total time spent on the day of the visit (using the new time ranges)
Use whichever method allows the highest appropriate reimbursement, however,
Certain categories may only have time as a reporting component (e.g., critical care).
Other may not have time as a component(e.g., emergency department) and are solely based
on MDM.
Problem
Prob lem
MDM
Risk Data
MDM
Medically Medically
Appropriate Appropriate
History Exam
Medical Decision Making
Chief Complaint – Reason for the visit
Brief
statement,
usually in the
patients own the
words, that Concise reason(s)
describes the statement
describing for the
reason the encounter.
patient is seeing
the physician.
Number/Complexity of Problems Addressed – Problem Minimal
Minimal
•A problem that may not require the presence of a provider, but the service is provided
under the provider’s supervision
Self-limiting or Minor Problem
•A problem that is temporary and runs a definite prescribed course, is temporary in nature,
and is not likely to permanently affect the patient’s health status
Number/Complexity of Problems Addressed – Problem Low
Stable, Chronic Illness
Acute, uncomplicated illness or injury requiring hospital inpatient or observation level care:
Low
❑2 or more self-limited or minor problems;
Or
❑1 stable, chronic illness Or
❑1 acute, uncomplicated illness or injury
Or
❑1 stable acute illness Or
❑1 acute, uncomplicated illness or injury requiring hospital inpatient
or observation level of care.
Number/Complexity of Problems Addressed – Problem Moderate
Chronic Illness with Exacerbation, Progression, or Side Effects of Treatment
Number/Complexity of Problems Addressed – Problem Moderate
Elements of Medical Decision Making
Number and Complexity of Problems Addressed
at the Encounter
Moderate
Acute
•An acute or Chronic
illness Illness
with systemic or Injury
symptoms, that complicated
an acute Poses a Threat
injury, to
or Life or Bodily
a chronic Function
illness or injury with exacerbation
and/or progression or side effects of treatment, that poses a threat to life or bodily function in the near term without
treatment. Some symptoms may represent a condition that is significantly probable and poses a potential threat to life
or bodily function. These may be included in this category when the evaluation and treatment are consistent with this
degree of potential severity
Question Answer
Can point of care tests that are results Yes, these simple tests that do not
only—such as dipstick UA, quick strep require separate interpretation can now
and CBC—be counted as ordered or be counted as order/review as part of
reviewed for selecting an MDM level even Data in MDM, even if the test was
if the CPT code is billed for those tests? reported by the physician/QHP
performing the office E/M
If a test does not require separate interpretation (e.g., results only tests) AND
• Is analyzed as part of the MDM
• Counts as 1 item towards ordered/reviewed in Data
Amount/Complexity of Data Reviewed & Analyzed
Data Complexity
Question Answer
Question Answer
Analyzed: Analyzed is a term describing the process of using the data as part of the MDM. The data
element itself may not be subject to analysis (eg, glucose), but it is instead included in the thought
processes for diagnosis, evaluation, or treatment. Tests ordered are presumed to be analyzed when the
results are reported. Therefore, when they are ordered during an encounter, they are counted in that
encounter. Tests that are ordered outside of an encounter may be counted in the encounter where they
are analyzed. In the case of a recurring order, each new result may be counted in the encounter at
which it is analyzed.
For example, an encounter that includes an order for monthly prothrombin times would count for one
prothrombin time ordered and reviewed. Additional future results, if analyzed in a subsequent
encounter, may be counted as a single test in that subsequent encounter. Any service for which the
professional component is separately reported by the physician or other qualified health care
professional reporting the E/M services is not counted as a data element ordered, reviewed, analyzed, or
independently interpreted for the purposes of determining the level of MDM
Analysing Clarified
Amount/Complexity of Data Reviewed & Analyzed
Data Complexity
reported)
•
Discussion requires an interactive exchange. The exchange
must be direct and not through intermediaries (e.g.,
clinical staff or trainees).
•
Sending chart notes or written exchanges that are within
progress notes does not qualify as an interactive exchange.
The discussion does not need to be on the date of the
encounter, but it is counted only once and only when it is
used in the decision making of the encounter.
•
It may be asynchronous (i.e., does not need to be in person),
but it must be initiated and completed within a short time
period (e.g., within a day or two).
Amount/Complexity of Data Reviewed & Analyzed
Amount/Complexity of Data Reviewed & Analyzed
•
A combination of different data elements, for example, a combination of notes reviewed, tests ordered,
tests reviewed, or independent historian, allows these elements to be summed. It does not require each
item type or category to be represented. A unique test ordered, plus a note reviewed and an independent
historian would be a combination of three elements.
•
Of course, an interpreter should not be considered an independent historian as they are simply relaying
information presented by the patient.
Amount/Complexity of Data Reviewed & Analyzed
A form of interpretation should be documented but need not conform to the usual standards of a complete report
for the test.
Amount/Complexity of Data Reviewed & Analyzed
Amount/Complexity of Data Reviewed & Analyzed
Chief Complaint: Est Patient here for follow-up Diabetes and Hypertension Patient presents today
for his 6-month follow-up to review his Type 2 DM and
Hypertension. His DM has been controlled on Metformin for 2 years. His HTN is controlled
with metoprolol, started 6 months ago. Patient checks BS and B/P daily and reports WNL. No
other s/s to report today.
CMP and HbA1C lab tests ordered.
B/P 130/80 EKG performed today, normal sinus rhythm.
Patients' wife states he had an abnormal diabetic eye exam recently but can not remember what
the ophthalmologist said. The report is not in the chart. I spoke with Dr. Smith (ophthalmologist)
and he advised that he saw some mild changes in the retina and has arranged to follow up with
the patient.
Amount/Complexity of Data Reviewed & Analyzed - Example
E X A M PL E
Data – High
Complexity
Risk of Complication and/or Morbidity or Mortality of Patient MGT
Definition of Risk
Risk of Complication and/or Morbidity or Mortality of Patient MGT
• Counseling
• Diet and Exercise
• EKGs and EEGs
• Rest
• Superficial bandages and
dressings
Minimal - • Urinalysis
• Ultrasounds, Echocardiogram
Risk
Risk factors are those that are relevant to the patient and procedure.
Risk of Complication and/or Morbidity or Mortality of Patient MGT
Chest x-rays,
CT/MRI w/o contrast
IV fluids w/o additives
Lab tests requiring
venipuncture
Low - Risk Minor surgery w/o risk factors
Over the counter drugs
Therapies (PT/OT, etc.)
Risk factors are those that are relevant to the patient and procedure.
Risk of Complication and/or Morbidity or Mortality of Patient MGT
Risk factors are those that are relevant to the patient and procedure.
Risk of Complication and/or Morbidity or Mortality of Patient MGT
Risk factors are those that are relevant to the patient and procedure.
Drug Therapy with Intensive Monitoring for Toxicity
A therapeutic agent which has the potential to cause serious morbidity or death
Monitoring should follow practice that is generally accepted for the drug but may
be patient specific in some cases.
If a provider considers a
treatment but chooses to not
The 2021 guidelines make it Patient non-compliance select that treatment,
clear that options considered, (Z91.19) may add to risk, documentation should
but not selected. providers should document support the reason why,
how. such as patient refusal,
patient is not a surgical
candidate, etc.
And
And /or
/or
Auditing Based on Time
•
Start and stop times are not required to be documented.
•
Providers should not list a range of time. When using time to level an
•
CPT® : “The appropriate time should be documented in the medical record when E/M, the time statement must be
it is used as the basis for code selection.” documented by provider within
•
If time is not documented, or is an insufficient time for the minimum code, MDM the note and must state their
must be used to level the encounter. best estimate of the exact time
spent in care of the patient on
the date of the encounter.
Shared or Split Visit Time
1 5 m i n utes us e
99202 99212 If <
M DM
15-29 mins 10-19 mins
99203 99213
30-44 mins 20-29 mins
99204 99214
45-59 mins 30-39 mins
99205 99215
60-74 mins 40-54 mins
Prolonged Services
C h a ng es
2 0 2 3 o m i ng CMS
C
Total time is the sum of all time, with and without direct patient contact and including prolonged
time, spent by the reporting practitioner on the date of service of the visit.
Use code 993X0 to report prolonged total time provided by the physician or GXXX3
QHP on the date of an inpatient (Nursing Facility, Observation or IP Consultation) E/M service, contact beyond
the required time of the primary service when the primary service level has been selected using total time,
each 15 minutes of total:
list separately in addition to CPT® codes 99223, 99233, 99236, 99255, 99306, 99310
Do not report 993X0 for any time unit less than 15 min
Do not report 993X0 on the same date of service as 90833, 90836, 90838, 99358, 99359)
For prolonged services on a date other than the date of a face-to-face evaluation and management
encounter with the patient and/or family/caregiver, see 99358, 99359.
*
Total time is the sum of all time, with and without direct patient contact and
including prolonged time, spent by the reporting practitioner on the date of service
of the visit.
Prolonged Services – 99358 & 99359 Codes
Total Duration of Prolonged Code(s)
Code(s) Services without
direct face-to-face Contact Codes 99358 and 99359 are used when a
Less than 30 minutes Not reported separately prolonged service in relation to a face-to-face
evaluation and management encounter with the
30-74 minutes 99358 X 1 patient and/or family/caregiver is provided on a
75-104 minutes 99358 X 1 and 99359 x 1 date other than the date of the E/M, whether
time was used to select the level of the face-to-face
105 or more minutes 99358 x 1 and 99358 x 2 or service.
more for each additional 30
minutes
Code Description Prolonged service without direct patient contact may only
99358 Prolonged evaluation and management be reported when it occurs on a date other than the date
service before and/or after direct patient of the evaluation and management service.
care; first hour For example, extensive record review may relate to a
previous evaluation and management service performed
+99359 Prolonged evaluation and management at an earlier date.
service before and/or after direct patient However, it must relate to a service or patient which (face-
care; each additional 30 minutes. to-face) patient care has occurred or will occur and relate
to ongoing patient management.
Prolonged Services
Code Description
99415 First hour
+99416 each additional 30 minutes
Prolonged Service – Clinical Staff
The starting point for 99415 is 30 minutes beyond the typical clinical staff time for ongoing assessment of
the patient during the office visit. The Reporting Prolonged Clinical Staff Timetable provides the typical
clinical staff times for the office or other outpatient primary codes, the range of time beyond the clinical
staff time for which 99415 may be reported, and the starting point at which 99416 may be reported.
Place of Service – Initial Hospital OR Observation
The following codes are used to report the first hospital inpatient (21) or observation (22)
status encounter with the patient.
Initial hospital inpatient or observation care, per day, for the evaluation and
management of a patient, which requires a medically appropriate history and/or
examination and MDM
Report
Outpatient Consultation Codes
The following codes may be used to report consultations that are provided in the office
(11) or other outpatient site (19/22), including the home or residence (12/13), or emergency
department (23).
Medicare does
NOT cover
consultations
Inpatient Consultation Codes
The following codes should be used to report consultations reported in hospital inpatients (21), observation-level
patients (22), residents of nursing facilities (31/32), or patients in a partial hospital setting, and when the
patient has not received any face-to-face professional services from the physician or other QHP or another
physician or other QHP of the exact same specialty and subspecialty who belongs to the same group practice
during the stay.
If a consultation is performed in anticipation of, or related to, an admission by another physician or other QHP,
and then the same consultant performs an encounter once the patient is admitted by the other physician or other
QHP, report the consultant’s inpatient encounter with the appropriate subsequent care code (99231, 99232, 99233).
• These codes should also be used to report evaluation and management services
provided to a patient in nursing facilities (32), skill nursing facilities (31), a
psychiatric residential treatment center (56) and immediate care facility for
individuals with intellectual disabilities (54).
• Regulations pertaining to the care of nursing facility residents govern the nature
and minimum frequency of assessments and visits. These regulations also govern
who may perform the initial comprehensive visit.
• Modifiers may be required to identify the principal physician from specialist
performing consultations or concurrent care.
(99318 Annual NF Assessment has been deleted. To report, see 99307, 99308, 99309,
99310)
Discharge Codes - Nursing Facility Care
•
The nursing facility discharge management codes are to be used to report the total
duration of time spent by a physician or other QHP for the final nursing facility
discharge of a patient
•
The codes include, as appropriate, final examination of the patient, discussion of the
hospital stay, instructions for continuing care to all relevant caregivers, and
preparation of discharge records, prescriptions, and referral forms.
•
These services require a face-to-face encounter with the patient and/or family/
caregiver that may be performed on a date prior to the date the patient leaves the
facility. Code selection is based on the total time on the date of the discharge
management face-to-face encounter
New Patient – Home or Residence Service
•
The following codes are used to report evaluation and management services provided in
a home or residence (12) to a new patient, which requires a medically appropriate
history and/or examination MDM.
•
Home may be defined as a private residence, temporary lodging, or short-term
accommodation (e.g., hotel, campground, hostel, or cruise ship). These codes are also
used when the residence is an assisted living facility (13), group home (14) (that is not
licensed as an intermediate care facility for individuals with intellectual disabilities),
custodial care facility (33) or residential substance abuse treatment facility (55).
•
99324, 99325, 99326, 99327, 99328 have been deleted.
The following codes are used to report evaluation and management services provided
in a home or residence to an established patient.
(99334, 99335, 99336, 99337 have been deleted. For domiciliary, rest home [eg,
boarding home], or custodial care services, established patient, see home or
residence services codes 99347, 99348, 99349, 99350)
These codes are also used when the residence is an assisted living facility (13), group
home (14) (that is not licensed as an intermediate care facility for individuals with
intellectual disabilities), custodial care facility (33), or residential substance abuse
treatment facility (55).