AMA CPT® Assistant - 2025 Issue 9 (September)
Coding Clarification: Reporting Online Digital E/M Services (98970-98972, 99421-99423)
September 2025 pages 1-20 Coding Clarification: Reporting Online Digital E/M Services (98970-98972, 99421-99423) The American Medical Association (AMA)/Specialty Society Relative Value Scale (RVS) Update Committee (RUC) determined that there is a need to clarify who should report codes 98970-98972 and 99421-99423. These codes were flagged for review because Medicare claims data show that codes 98970-98972 were predominantly reported by physicians and other qualified health care professionals (QHPs) who may report evaluation and management (E/M) services, raising concerns that physicians or other QHPs who report these services may be inadvertently reporting the time of their clinical staff. This article provides...
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Article Overview
This article explains how CPT distinguishes two sets of patient-initiated online digital services and why payer data prompted clarification from the AMA/RUC. It is relevant to physicians, other qualified health care professionals, and nonphysician clinicians who document or report time-based, non-face-to-face digital communications in outpatient or other ambulatory settings. The discussion focuses on general categories of guidance, including service structure, provider eligibility, time frames, and reporting cautions.
Why This Topic Matters
Correct understanding of these CPT categories supports consistent documentation, compliance, and accurate reporting of digital care services. The article is especially useful for organizations reviewing workflows for clinicians who may or may not report E/M services.
Article Sections
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September 2025 pages 1-20
Publication and issue information for the article.
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Coding Clarification: Reporting Online Digital E/M Services (98970-98972, 99421-99423)
Introductory overview of the clarification topic and the reason the article was developed.
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Non-Face-to-Face Services
Background on online digital services and how they are organized within CPT.
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Online Digital Evaluation and Management Services
General discussion of the E/M service category, provider eligibility, timing framework, and related reporting considerations.
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Medicine
General discussion of the corresponding Medicine-section service category and its relationship to the E/M category.
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Nonphysician Qualified Health Care Professional Online Digital Assessment and Management Service
General discussion of the assessment-and-management category for nonphysician clinicians and its reporting context.
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Table 1. Comparing Codes 99421-99423 and 98970-98972: Distinctions and Similarities
A side-by-side comparison of the two CPT code groups across provider type, patient status, time period, and time-based structure.
What You Will Learn
- How CPT separates online digital services into two broad categories
- Which types of clinicians are associated with each category
- How the services are structured around patient initiation and cumulative time
- What documentation and reporting issues prompted the clarification
- How the article compares the two code groups at a high level
Who Should Read This
- Physicians
- Other qualified health care professionals
- Nonphysician qualified health care professionals
- Professional coders
- Clinical documentation staff
- Compliance teams
- Revenue cycle teams
Codes Discussed
Code Ranges Discussed
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