E/M Coding Changes of 2021
The AMA collaborated with partners like AGA and our sister GI organizations in developing the new E/M guidelines. It reduces the criteria for reporting and expedites distinguishing payments based on the complexity of treatment. The Centers for Medicare & Medicaid Services (CMS) announced that it would follow the recommendation of the AMA and their proposed relative values for CPT E/M codes for 2021 during the 2020 Medicare Physician Fee Schedule (MPFS) final regulation. There will also be small rate changes that could help those who treat patients with complicated conditions.
The addition of a 15-minute extended service code that can be registered with 99205 and 99215, the removal of code 99201 (Level 1 new patient access), and the subsequent redesign of the office visit code selection are the most significant changes to office/outpatient E/M visits:
1. New history and physical removal elements for code collection
While it is clinically important to acquire a specific history and conduct a relevant physical evaluation that leads to both time and medical decision-making, these elements would not be factored in code selection. Instead, only patient decision-making or time can decide the code standard.
2. Adjustment of the MDM criteria
The new CMS Risk Table was used as the basis for the specification of the updated requested MDM components.
- Terms.
Erased vague words (e.g., "mild") and established definitions that were formerly vague (e.g., "acute or chronic systemic symptom disease").
- Definitions.
Established the definition of important terms, such as “independent historian.”
- Data elements.
The data components were reinterpreted to shift away from merely incorporating tasks to concentrating on how certain tasks impact the patient's management (e.g. independent analysis of a test conducted by another physician and/or conversation with another doctor on the interpretation of the test).
3. Option to use medical decision-making (MDM) or complete-time as the basis of reporting of the E/M level:
- Time.
The interpretation of time is no minimum time, not "face-to-face" time or standard time. The minimum time on the day of operation reflects cumulative physician/qualified health care provider time. This redefinition of time makes it easier for Medicare to better appreciate the work involved with non-face-to-face programs, such as coordination of treatment and record analysis. Of note, these concepts only apply where the option of code is time-based and not MDM-based.
- MDM.
Although three MDM subcomponents (number/complexity of problems, data, and risk) will still exist, substantial changes have been made to how these components are described and counted.
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