E/M Changes in 2021 for 99202-99215 | Overview

• Medicare adopts CPT^® E/M changes for 2021, rescinding the plan for bundled payment for three levels of codes
• Clinicians can select new and established patient visit based on time or medical decision making (MDM)
• New guidelines for using time for 99202—99215, new definitions in MDM
• Revised MDM guidelines

Many physicians and medical societies were dismayed that CMS planned to adopt a single RVU value and bundled payment for codes 99202—99204, and codes 99212—99214 in 2021, as Medicare proposed in 2019.

The American Medical Association (AMA) strongly disagreed, and the AMA’s CPT^® panel got to work on revisions. It takes time to revise CPT^® codes and definitions., but the CPT^® editorial panel made changes in 2019 that will take effect in 2021. There wasn’t time to put these changes in the 2020 book, and the guidelines and code definitions are unchanged in 2020 for 99201-99215.

The changes below relate only to new and established patient visits in 2021, codes 99202—99215.

• Code 99201 will be deleted.
• Clinicians may use either time or medical decision making to select a code.
• There will be no required level of history or exam for visits 99202—99215. From the AMA website for 2021,

“Office or other outpatient services include a medically appropriate history and/or physical examination, when performed. The nature and extent of the history and/or physical examination is determined by the treating physician or other qualified health care professional reporting the service. The care team may collect information and the patient or caregiver may supply information directly (eg, by portal or questionnaire) that is reviewed by the reporting physician or other qualified health care professional. The extent of history and physical examination is not an element in selection of office or other outpatient services.”

• Time will be defined as total time spent, including non-face-to-face work done on that day, and will no longer require time to be dominated by counseling.
• Visits will have a range for time, e.g., 99213 will be 20-29 minutes, 99214 will be 30-39 minutes
• There will be new definitions within MDM.
• The MDM calculation will be similar to, but not identical to, the current MDM calculation.
• CPT^® is providing numerous definitions to clarify terms in the current guidelines, such as “chronic illness with exacerbation, progression or side effects of treatment,” and “drug therapy requiring intensive monitoring for toxicity.”

There was a hint in the Physician Proposed Fee Schedule rule that the CPT^® Editorial panel was continuing its work on E/M services.  Will we see changes to other categories of E/M services in 2022?

All other E/M services that are defined by the three key components will continue to use the 1995 and/or 1997 Documentation Guidelines, not just in 2020, but in 2021.

Members, you can read three in-depth articles about the 2021 changes.

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