2021 E/M coding: Addressing confusion surrounding MDM

March 23rd, 2021

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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 premium article explains outpatient E/M coding changes effective in 2021, with emphasis on medical decision-making as a basis for level selection and on the documentation issues that have created confusion. It is aimed at coders, billers, compliance staff, and clinicians who need to understand how the revised guidance affects data review, ordering and interpretation of tests, prolonged service reporting, and audit risk. The discussion also summarizes the broader impact of payer guidance and professional society corrections on outpatient visit coding.

Why This Topic Matters

The article helps readers understand why outpatient E/M level selection changed, where confusion remains, and which documentation and auditing areas are most likely to affect claims review.

Article Sections

  1. Overview of 2021 outpatient E/M level selection

    Introduces the revised outpatient visit framework and the role of medical decision-making in level selection. Summarizes the three MDM elements and how they relate to overall visit complexity.

  2. Interpreting the guidelines for data review

    Discusses revisions and clarifications affecting the data review component of MDM. Covers the general treatment of diagnostic testing services, professional interpretation, and related guidance from professional organizations.

  3. Billing considerations

    Reviews payment and billing issues that influence how test ordering is viewed under the revised guidance. Addresses the broader administrative context and why facility versus practice billing relationships matter.

  4. Audit issues

    Summarizes potential audit concerns related to time-based reporting, prolonged services, and MDM documentation. Notes areas where payer review may focus on documentation consistency and supporting records.

What You Will Learn

  • How outpatient E/M level selection changed in 2021
  • What the MDM elements cover at a high level
  • Why data review documentation has been a source of confusion
  • Which billing and audit areas are drawing attention under the revised guidance
  • How prolonged services and time-based reporting are discussed in relation to audits

Who Should Read This

  • Medical coders
  • Coding auditors
  • Compliance staff
  • Physician practices
  • Hospital outpatient billing teams
  • Clinicians involved in documentation

Codes Discussed

  • CPT: 99358
  • CPT: 99359
  • CPT: 99417
  • CPT: 99205
  • CPT: 99215

Code Ranges Discussed

  • CPT: 99358-99359

Modifiers Discussed

  • CPT: -26

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