by Wyn Staheli, Director of Research
March 16th, 2021
On March 9, 2021, the American Medical Association (AMA) announced some pretty significant changes in relation to reporting Evaluation and Management (E/M) services, particularly for Office or Other Outpatient Services (99202-99215). As is commonly the case, once the new guidelines began being used on a regular basis, questions were raised and clarification was needed. The AMA Editorial Panel met to discuss how to address concerns and made changes surrounding Office or Other Outpatient Services which are retroactive to January 1st.
Note: There were also major revisions made to other E/M services (i.e., inpatient, observation, consultations, emergency department, nursing facility, rest home, prolonged services) which are scheduled to take place on January 1, 2023. Further information on these changes will be addressed in the future.
What Changed with MDM?
According to the announcement by the AMA, the following revisions were made regarding medical decision making (MDM):
- Clarifying when reporting a test that is considered, but not selected after shared decision making.
- Providing a definition of “Analyzed” for reporting tests in the data column.
- Clarifying the definition of a “unique” test.
- Clarifying what is meant by “discussion” between physicians, and other qualified health care professionals and patients.
- Providing a definition of major vs. minor surgery.
- Clarification around which activities are not counted when reporting time as a key criterion for code level selection.
What About Medicare?
Although Medicare adopts most changes made by the AMA, there are sometimes differences in opinion (e.g., 99417 vs G2212) so it is not always a given that they will incorporate all of these changes. We have contacted Noridian and a representative stated that they are aware of the changes and are planning on posting information about it on their website once a decision has been made. However, it is unknown just how long it will take them to post a decision so watch for announcements from your local Medicare Administrative Contractor (MAC) and check their website.
What Can I do Now?
For providers already struggling with making the previously announced changes, this might seem a little overwhelming, but there are some things you can do to understand what was revised.
Errata and Technical Corrections: Periodically, the AMA publishes an official document which shows what corrections they have made to the CPT codebook. This document includes ALL corrections to the 2021 CPT codebook and codeset which means it also includes information on other updates (e.g., vaccines). The drawback is that the information is not shown in context. To gain a better understanding of these revisions , consider the Online and Training options listed below.
Online: FindACode.com has already incorporated these guideline changes so they are immediately available to all subscribers by CLICKING HERE. Also note that they may be viewed at the code level by clicking on the [CPT Chapter/Section Guidelines & Notes] bar to see them. However, this is the complete listing so it doesn't really have an outline of what changed, just what it currently looks like.
Training: FindACode is offering a FREE webinar on March 25 at 10:15 AM PST, which will help your organization better understand these changes and their potential impact, especially considering that it applies retroactively to January 1, 2021 – meaning that previously submitted claims may need to be reviewed. CLICK HERE to get registered today!
We are currently updating our Evaluation and Management products to incorporate all these changes. The new Third Edition of the Evaluation and Management Comprehensive Guide will be available soon and may be purchased in our online store.