E/M update: Navigate new vs. established patient distinctions during COVID-19

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Note:  The following article synopsis was NOT provided by HCPro. It was created by Find-A-Code/innoviHealth.

Article Overview

This article discusses how COVID-19 public health emergency policy affected patient-status requirements for certain evaluation and management services. It is aimed at coding and billing staff, auditors, and clinicians who report telehealth and other virtual E/M services and need to understand the general scope of temporary CMS enforcement discretion, related service categories, and the time-limited context of these changes.

Why This Topic Matters

Patient-status distinctions can affect whether a service is reportable under a given code and how telehealth claims are reviewed during the public health emergency. Understanding the article helps practices apply CMS guidance consistently and prepare for later audits or policy changes.

Article Sections

  1. COVID-19 PHE and patient-status enforcement discretion

    Introduces the public health emergency context and CMS guidance related to established-patient language in certain virtual E/M services. It frames the temporary policy environment discussed in the article.

  2. New vs. established matters for telehealth

    Explains why patient status still needs to be checked for telehealth services with separate new- and established-patient structures. It also summarizes the service categories affected during the emergency period and notes the temporary nature of the coverage changes.

What You Will Learn

  • How the COVID-19 public health emergency affected patient-status considerations for selected E/M services
  • Which broad telehealth service categories were discussed in relation to new and established patient distinctions
  • Why practices may track claims internally during a temporary policy period
  • How CMS guidance and the Medicare Claims Processing Manual are referenced in the discussion

Who Should Read This

  • Medical coders
  • Billing staff
  • Revenue cycle teams
  • Compliance/audit personnel
  • Clinicians reporting E/M services

Codes Discussed

Code Ranges Discussed


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