6 Big Changes Coming for Office-Visit Coding

Betsy Nicoletti, MS

Disclosures

December 01, 2020

Betsy Nicoletti, MS, a nationally recognized coding expert, will take your coding questions via email and provide guidance on how to code properly to maximize reimbursement. Have a question about coding? Send it here.

Physicians will soon start having an easier time — and perhaps get paid more money — when they code for evaluation and management (E/M) services, thanks to the American Medical Association (AMA).

The first major changes to the definitions for E/M services will be in effect as of January 1, 2021, with all payers expected to adopt these new guidelines. In particular, the AMA has revised the definitions for E/M codes 99202–99215 in the Current Procedural Terminology (CPT) 2021 codebook. The existing guidelines were developed in 1995 and 1997 and remain in effect for all other E/M services determined by history, exam, and medical decision-making (MDM).

What do the new changes mean to you? In 2021, for new and established office and other outpatient services reported with codes 99202–99215, a clinician may select the code on the basis of time or MDM.

There are three elements in MDM, and two of three are required. These elements are the number and complexity of problems addressed, amount and/or complexity of data to be reviewed and analyzed, and risk of complications and/or morbidity or mortality of patient management. (You can download a copy of the AMA grid here.)

Make sure you familiarize yourself with these six big changes. It may take a bit of time to integrate these new processes into your daily routine, but wrapping your head around them as soon as possible can help boost your bottom line:

1. History and exam don't count toward level of service

Physicians, advanced practice registered nurses, and physician assistants won't use history or exam to select what level of code to bill for office visits 99202–99215, as they did in the past. They need only document a medically appropriate history and exam. The history may be obtained by staff members and reviewed by the billing practitioner.

While specific history and exam requirements disappear for office visit codes, they remain for all other types of visits, selected on the basis of history, exam, and MDM, such as hospital services, nursing facility services, and home and domiciliary care. So, say goodbye to "all other systems reviewed and negative" in office notes, but keep it handy for those other E/M codes.

2. All time spent caring for the patient on a particular day counts

This includes all time spent on the day of service, including preparing to see the patient, seeing the patient, phone calls or other work done after the visit (if not billed with a care management or other CPT code), and documenting in the medical record. The AMA developed new guidelines for using time for office and other outpatient services. For codes 99202–99215, count all of the face-to-face and non–face-to-face time spent by the billing clinician on the day of the visit. Counseling does not need to be more than 50% of the total time.

Do not include any staff time or time spent on any days before or after the visit. This allows clinicians to capture the work when a significant amount of it takes place before or after the visit with the patient, and to bill for it on the day of the visit.

According to the 2021 CPT codebook, physician or other qualified healthcare professional time includes the following activities*:

  • preparing to see the patient (eg, review of tests)

  • obtaining and/or reviewing separately obtained history

  • performing a medically appropriate examination and/or evaluation

  • counseling and educating the patient/family/caregiver

  • ordering medications, tests, or procedures

  • referring and communicating with other healthcare professionals (when not separately reported)

  • documenting clinical information in the electronic or other health record

  • independently interpreting results (not separately reported) and communicating results to the patient/family/caregiver

  • care coordination (not separately reported)

*American Medical Association. CPT 2021 Professional Edition. AMA; 2020:8.

The codes now have time ranges, in place of a single threshold time.

Code Time range   Code Time range
99202 15-29 minutes   99212 10-19 minutes
99203 30-44 minutes   99213 20-29 minutes
99204  45-59 minutes   99214  30-39 minutes
99205  60-74 minutes   99215 40-54 minutes

3. Soon to be gone: "new to the examiner" and "workup planned"

The current guidelines don't differentiate between a new problem to the clinician or an established problem to the clinician. So it doesn't matter whether you're hearing about a particular problem for the first time or the fifth time. The new office and outpatient services guidelines define problems only as they relate to the patient. For example, when selecting a level of service, a chronic problem with a mild exacerbation is the same level whether it's the primary care physician seeing the patient for the 10th time to help manage her diabetes or the endocrinologist seeing the patient for the first time.

In the current guidelines (1995 and 1997), additional weight is given in selecting the level of MDM for a problem that's new to the examiner with a workup planned, yet when the diagnostic test couldn't be completed at the visit. This concept is gone from element of number and complexity of new problems. Ordering diagnostic tests is part of the second element, the amount and/or complexity of data to be reviewed.

4. Different guidelines if you need a history from a parent or other source

The new guidelines recognize the additional work required by the clinician when the patient is unable to give a history or when the practitioner doesn't find the history to be reliable.

For example, in the case of a baby or child who is unable to give a history, the parent counts as an "independent historian," according to the new guidelines. Likewise, for a patient with dementia, the caregiver counts as a historian. Note, however, that the criteria is not met simply because the patient is accompanied by another person. The additional weight in selecting the level of service is based on the patient being unable to give a reliable history.

Bottom line: In cases where patients are unable to communicate clearly, physicians or other providers should document the necessity of getting a complete history and who provided it.

5. A new spin on social determinants of health (SDoH)

In the risk of morbidity and/or mortality element, conditions described as "social determinants of health" are considered moderate complexity. SDoH are social and environmental factors that affect a patient's health and medical outcomes. These include homelessness, inability to afford medications, food insecurity, and occupational exposure to risk factors. These circumstances are reported with codes in categories Z55–Z65.

In the past, physicians often documented this information in their office notes but rarely added a diagnosis code that described the patient's situation. The ICD-10-CM code set includes codes that describe these factors. Using them allows the practice to track patients who have increased needs, and it communicates to payers the complexity of caring for these patients.

6. Risks related to surgery are defined

The current guidelines assign different levels of risk to minor and major surgery. They also include differentiation for "minor surgery with no identified risk factors," "minor surgery with identified risk factors," "elective major surgery with no identified risk factors," and "elective major surgery with identified risk factors." The old guidelines didn't state whether the risk factors pertained to the patient — such as smoking, heart disease, or high body mass index — or to the procedure itself.

The new guidelines specifically say that it's both. In the risk column, "decision regarding minor surgery with identified patient or procedure risk factors" and "decision regarding elective major surgery without patient or procedure risk factors" are both considered moderate. "Decision regarding elective major surgery with identified patient or procedure risk factors" and "decision regarding emergency major surgery" are in the high complexity column for risk.

Keep in mind that two of three elements are required: the number and complexity of problems, amount of data, and morbidity/mortality risk. Risk of morbidity/mortality alone doesn't count as the basis for selecting the code. Of course, when surgeons see this, they ask, "What major procedures don't have identified risk factors?"

Note, too, that these new CPT guidelines do not define the terms "minor" and "major" surgery. For payment reasons related to the post-op period, the Centers for Medicare & Medicaid Services defines minor surgery as a procedure with 0-10 global days and a major surgery as a procedure with 90 global days. However, there are many procedures with 0 global days (endoscopy, cardiac catheterization) that are not minor procedures. Hopefully, the AMA will clarify this in 2021.

What's the Take-away for Clinicians?

There are sure to be shifts in coding patterns based on these new guidelines. Some specialties will find that not being able to select a service based on history and exam alone will lower the level of service they can bill for. Some practices, on the other hand, will be able to code for more high-level visits, without the need for a complete review of systems or a comprehensive exam.

The biggest challenge will be for practices that provide services both in the hospital and in the office, because they'll have to use both sets of guidelines, depending on which type of service they're performing.

For more details on what's coming your way beginning on New Year's Day, you may want to read the 16-page AMA document.

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