Effective 1/1/2021 the AMA is making changes to the Office or Other Outpatient Services E/M codes 99202 through 99215. They are eliminating code 99201 completely. This is a brief summary of the changes, but fist please note that these are the only E/M codes affected.  All other E/M codes, inpatient hospital, emergency room, critical care, observation, consults, etc. are still coded based on the present criteria. One important fact to remember is that these are AMA CPT changes, not CMS so they apply to anyone who uses CPT.

What are the changes to the Office/Outpatient codes? The major one is that medical decision making or time will drive the code selection.  While history and exam must still be documented “bullet points” for these elements are no longer counted. The AMA states that these must be clinically relevant to the presenting problem.

Documentation becomes even more important since now the thought process used must be clearly demonstrated.

The AMA is using the same Table of Risk with some modifications to definitions.  There are still four levels of MDM, straightforward, low, moderate and high. The same three elements must be met, 1) number and complexity of problem(s) addressed in the encounter, 2) The amount and/or complexity of data reviewed, 3) the risks of complications, morbidity and/or mortality. The requirement that two of these three elements be met for the visit to qualify for a level remains the same. If coding based on time you are no longer required to document that over 50% was spent in counseling, however the amount of time must be documented whether it’s done as from – to or total amount of time spent.

Doreen Clark, CPC, CPMA