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2023 Evaluation &

Management Updates
(AMA Updates)
Padmaja Chilaka CPC,CPMA
2023 E/M
Guidelines
Disclaimer
This presentation is designed to offer basic information for
coding and billing. The information presented here is based
on the experience, training and interpretation of the author.
Although the information has been carefully researched and
checked for accuracy and completeness, the instructor does
not accept any responsibility or liability with regard to errors,
omissions, misuse or misinterpretation. This material is
intended as an Educational guide and should not be
considered a legal/consulting opinion.
Evaluation and Management
E VA L U AT I O N A N D M A N A G E M E N T C O D I N G , T O D AY A N D T O M O R R O W

1997-2010
1992 1995 July 1, 2022
Refining of
AMA created CMS Published AMA finalized 2023
Guidelines (2000
E/M codes Calculations E/M revisions
proposal rejected)

Nov. 1, 2019
1994 1997
CMS Revision of
CMS finalized 2021 office
Marshfield and other outpatient
Calculations
Clinic Beta Tool E/M revisions
(implementation
1/1/2021)
Deleted & Revision Codes

Evaluation and Management Categories for face-to-face encounter with the patient
and/or family:
•Office or Other Outpatient Services
•For 99211, the face-to-face services may be performed by clinical staff
•Hospital Inpatient and Observation Care Services
•Consultations
•Emergency Department Services
•For 99281, the face-to-face services may be performed by clinical staff
•Nursing Facility Services
•Home or Residence Services
•Prolonged Service With or Without Direct Patient Contact on the Date of an
Evaluation and Management Service
Deleted & Revision Codes

Deleted Additions/Revisions
99217 - OBS Discharge 99238, 99239
99218 - 99220 - Initial OBS 99221 - 99223
99224 - 99226: Subsequent OBS 99231 - 99233
99241 & 99251: Outpatient & Inpat Consultations 99242
99318: Nursing Facility Service 99307 - 99310
99324 - 99328: Domiciliary, rest Home, Custodial New Patient 99341, 99342, 99334 , 99345

99334 - 99337: Domiciliary, rest Home, Custodial Est Patient 99347 - 99350

99339 - 99340: Domicilliary, rest Home, Home Care CPO 99437, 99491, 99424, 99425
99343: Home or Residence Services 99341 - 99345
99356 - 99357: Prolonged Service Inpatient pr OBS 993X0
New & Established Patient

New Vs Established

Nurse Practitioners and


Physician Assistants
working with physicians,
they are considered as
working in the exact
same specialty and
subspecialty as the
physician.
Covering or “on-
call” providers
should select the
relationship code
the unavailable
provider would
have used.
Initial vs Subsequent
MDM & Time

Coders and providers are required to choose E/M visit levels based on either:
 Medical Decision Making (using the new office/OP revisions MDM table) or
 Total time spent on the day of the visit (using the new time ranges)

Use whichever method allows the highest appropriate reimbursement, however,


 Certain categories may only have time as a reporting component (e.g., critical care).
 Other may not have time as a component(e.g., emergency department) and are solely based
on MDM. Problem

Problem

MDM

Risk Data
MDM

Medically Medically
Appropriate Appropriate
History Exam
Medical Decision Making
Chief Complaint – Reason for the visit

Brief
statement,
usually in the
patients own the
words, that Concise
statement reason(s)
describes the
describing for the
reason the
patient is seeing encounter.
the physician.
Number/Complexity of Problems Addressed – Problem Minimal
Minimal
•A problem that may not require the presence of a provider, but the service is provided
under the provider’s supervision
Self-limiting or Minor Problem
•A problem that is temporary and runs a definite prescribed course, is temporary in
nature, and is not likely to permanently affect the patient’s health status

Elements of Medical Decision Making


Number and Complexity of
Level of MDM (Based on 2 out of 3
Code Problems Addressed at the
Elements of MDM)
Encounter
99211 N/A N/A or Minimal
99202 Straightforward  Minimal
99212  1 self-limited or minor problem
Number/Complexity of Problems Addressed – Problem Low
Stable, Chronic Illness

Acute, Uncomplicated Illness or Injury

Acute, uncomplicated illness or injury requiring hospital inpatient or observation level care:

Stable, acute illness


Number/Complexity of Problems Addressed – Problem Low

Elements of Medical Decision Making


Number and Complexity of Problems Addressed
at the Encounter

Low
❑2 or more self-limited or minor problems;
Or
❑1 stable, chronic illness Or
❑1 acute, uncomplicated illness or injury
Or
❑1 stable acute illness Or
❑1 acute, uncomplicated illness or injury requiring hospital
inpatient or observation level of care.
Number/Complexity of Problems Addressed – Problem Moderate
Chronic Illness with Exacerbation, Progression, or Side Effects of Treatment
Number/Complexity of Problems Addressed – Problem Moderate
Elements of Medical Decision Making
Number and Complexity of Problems Addressed
at the Encounter
Moderate

❑1 or more chronic illnesses with exacerbation, progression, or side effects of


treatment;
Or
❑2 or more stable chronic illnesses;
Or
❑1 undiagnosed new problem with
uncertain prognosis;
Or
❑1 acute illness with systemic symptoms;
Or
❑1 acute complicated injury
Number/Complexity of Problems Addressed – Problem High
Chronic Illness with Severe Exacerbation, Progression, or Side Effects of Treatment
•The severe exacerbation or progression of a chronic illness or severe side effects of treatment that have significant risk of
morbidity and may require escalation in level of care.
Acute or Chronic Illness or Injury that Poses a Threat to Life or Bodily Function

Acute or Chronic Illness or Injury that Poses a Threat to Life or Bodily Function
•An acute illness with systemic symptoms, an acute complicated injury, or a chronic illness or injury with exacerbation
and/or progression or side effects of treatment, that poses a threat to life or bodily function in the near term without
treatment. Some symptoms may represent a condition that is significantly probable and poses a potential threat to life or
bodily function. These may be included in this category when the evaluation and treatment are consistent with this
degree of potential severity
Elements of Medical Decision Making
Number and Complexity of Problems Addressed at the Encounter

High
❑1 or more chronic illnesses with severe
exacerbation, progression, or side
effects of treatment;
Or
❑1 acute or chronic illness or injury that
poses a threat to life or bodily function
Number/Complexity of Problems Addressed

• The complexity of the presenting problem, TODAY. For example,


Hypertension (HTN) (I10)
Number/Complexity of Problems Addressed – Problem High

• Nature of the condition.


• Self-limiting or minor patients
whose recovery may not require
treatment or medication
intervention.
• Patients where the natural course of
a condition may be considered self-
limiting, minor or acute, but for a
specific patient where the condition
warrants chronic treatment to
improve and become stable,
document the treatment goal and
the supporting exceptions for the
problem complexity.
Number/Complexity of Problems Addressed

• Symptoms that may cluster around a


specific diagnosis are not necessarily a
unique condition, such as fever as the
result of flu.
• If symptoms are all expected to be related
to one problem (even if there is not yet an
established diagnosis) the symptoms
should not be counted separately, unless
provider states they are not likely to be
from the same source.
Services Reported Separately

• The ordering and actual performance and/or interpretation of diagnostic


test/studies during a patient encounter are NOT included in determining
the levels of E/M services when the professional interpretation of those
test/studies is reported separately by the physician or other QHP
reporting the E/M service.
Reporting of tests – Independent interpretation & ordered/reviewed

Question Answer

Can point of care tests that are results Yes, these simple tests that do not
only—such as dipstick UA, quick strep require separate interpretation can now
and CBC—be counted as ordered or be counted as order/review as part of
reviewed for selecting an MDM level Data in MDM, even if the test was
even if the CPT code is billed for those reported by the physician/QHP
tests? performing the office E/M

If a test does not require separate interpretation (e.g., results only tests) AND
• Is analyzed as part of the MDM
• Counts as 1 item towards ordered/reviewed in Data
Amount/Complexity of Data Reviewed & Analyzed

Data Complexity

Category 1: Tests and documents


• Any combination of from the following:
 Review of prior external note(s) from each unique source*;

An external physician or other


A unique source is defined as: QHP who is not in the same group
practice or is of a different
External records, communications a physician or qualified heath care
specialty or subspecialty.
and/or test results are from: professional in a distinct group or
different specialty or subspecialty, or This includes licensed
an external physician, other
a unique entity. professionals who are practicing
QHP, facility, or
independently.
health care organization. Review of all materials from any
unique source counts as one The individual may also be a
element toward MDM. facility or organizational provider
such as from a hospital, nursing
facility, or home health care
agency.
Clarifying reporting of tests – Unique Test

Question Answer

If my health system uses a single EMR and


I as a primary care physician review 3
notes from the cardiology group in my It is one unique document as it is a series
system that were since my last visit, is it: from one group. The intent of unique
one unique document because it is the source is to use the same group/same
same group, three because it is 3 items I specialty concept.
have not counted before or none because
we are all using the same source?
Amount/Complexity of Data Reviewed & Analyzed
Data Complexity
Category 1: Tests and documents, Cont.,
❑Review of the result(s) of each unique test*;
• Tests are imaging, laboratory, psychometric, or physiologic data.
A unique test is defined by the CPT® code set (81002, 93000)
• Tests that are ordered outside of an encounter may be counted in
the encounter in which they are analyzed. In the case of a
recurring order, each new result may be counted in the encounter
in which it is analyzed.
❑Ordering of each unique test*
Tests ordered are presumed to be analyzed when the results are
reported. Therefore, when they are ordered during an encounter,
they are counted in that encounter. The review of the test at a
subsequent encounter does not count during that second
encounter. *Includes tests considered but not executed.
*CPT Assistant Nov 2020, pg. 5
Reporting of tests – Independent interpretation & ordered/reviewed

Question Answer

Based on the E/M office visit guidelines,


If the test (in this case the X-ray) is being
when a physician in a group practice orders
separately reported by the physician who is
and performs a diagnostic x-ray, including
also reporting the E/M service, the
interpretation and report of the resulting
order/review of the test may not be used as
image, and subsequently submits a claim for
an MDM data element for selection of the
that, is it appropriate to count "Ordering of
E/M level of service. A chest x-ray requires
Each Unique Test" but not “Review of the
an interpretation and is not a “result” only
Results of Each Unique Test” when
study
determining Data in MDM?
Clarifying Reporting of Tests

Amount and/or Complexity of Data to be Reviewed and Analyzed

Analyzed: Analyzed is a term describing the process of using the data as part of the MDM. The data
element itself may not be subject to analysis (eg, glucose), but it is instead included in the thought
processes for diagnosis, evaluation, or treatment. Tests ordered are presumed to be analyzed when the
results are reported. Therefore, when they are ordered during an encounter, they are counted in that
encounter. Tests that are ordered outside of an encounter may be counted in the encounter where
they are analyzed. In the case of a recurring order, each new result may be counted in the encounter at
which it is analyzed.

For example, an encounter that includes an order for monthly prothrombin times would count for one
prothrombin time ordered and reviewed. Additional future results, if analyzed in a subsequent
encounter, may be counted as a single test in that subsequent encounter. Any service for which the
professional component is separately reported by the physician or other qualified health care
professional reporting the E/M services is not counted as a data element ordered, reviewed, analyzed, or
independently interpreted for the purposes of determining the level of MDM
Analysing Clarified
Amount/Complexity of Data Reviewed & Analyzed
Data Complexity

Category 1 and/or 2: Assessment requiring an independent historian(s)


Category 1 and/or 2: Assessment requiring an independent historian(s)
❑An individual (e.g., parent, guardian, surrogate, spouse, witness) who provides a history in
addition to a history provided by the patient who is unable to provide a complete or reliable
history (e.g., due to developmental stage, dementia, or psychosis) or because a confirmatory
history is judged to be necessary.
• In the case where there may be conflict or poor communication between multiple historians
and more than one historian is needed, the independent historian requirement is met. It
does not include translation services. The independent history does not need to be obtained
in person
Or

Category 2: Independent interpretation of tests


Category 2: Independent interpretation of tests
❑The interpretation of a test for which there is a CPT® code, and an interpretation or report is
customary. This does not apply when the physician or other QHP who reports the E/M service
is reporting or has previously reported the test. A form of interpretation should be
documented but need not conform to the usual standards of a complete report for the test.
Amount/Complexity of Data Reviewed & Analyzed
Data Complexity
Category 3: Discussion of management or
test interpretation
 Discussion of management or test interpretation with external
physician/other QHP\appropriate source (not separately
reported)
• Discussion requires an interactive exchange. The exchange
must be direct and not through intermediaries (e.g., clinical
staff or trainees).
• Sending chart notes or written exchanges that are within
progress notes does not qualify as an interactive exchange.
The discussion does not need to be on the date of the
encounter, but it is counted only once and only when it is
used in the decision making of the encounter.
• It may be asynchronous (i.e., does not need to be in
person), but it must be initiated and completed within a
short time period (e.g., within a day or two).
Amount/Complexity of Data Reviewed & Analyzed
Amount/Complexity of Data Reviewed & Analyzed

• A combination of different data elements, for example, a combination of notes reviewed, tests ordered,
tests reviewed, or independent historian, allows these elements to be summed. It does not require each
item type or category to be represented. A unique test ordered, plus a note reviewed and an
independent historian would be a combination of three elements.
• Of course, an interpreter should not be considered an independent historian as they are simply
relaying information presented by the patient.
Amount/Complexity of Data Reviewed & Analyzed

 A form of interpretation should be documented but need not conform to the usual standards of a complete report
for the test.
Amount/Complexity of Data Reviewed & Analyzed
Amount/Complexity of Data Reviewed & Analyzed

Chief Complaint: Est Patient here for follow-up Diabetes and Hypertension Patient
presents today for his 6-month follow-up to review his Type 2 DM and
Hypertension. His DM has been controlled on Metformin for 2 years. His HTN is controlled
with metoprolol, started 6 months ago. Patient checks BS and B/P daily and reports WNL. No
other s/s to report today.
CMP and HbA1C lab tests ordered.
B/P 130/80 EKG performed today, normal sinus rhythm.
Patients' wife states he had an abnormal diabetic eye exam recently but can not remember
what the ophthalmologist said. The report is not in the chart. I spoke with Dr. Smith
(ophthalmologist) and he advised that he saw some mild changes in the retina and has arranged
to follow up with the patient.
Amount/Complexity of Data Reviewed & Analyzed - Example
E X A M PL E

Category 1: Tests and documents


Any combination of 3 from the following:

•Review of prior external note(s) from each unique source*;


•review of the result(s) of each unique test*;
•ordering of each unique test*
•Assessment requiring an independent historian(s)
or
Category 2: Independent interpretation of tests

1. Ordered CMP •Independent interpretation of a test performed by another


2. Ordered HgA1c physician/other QHP (not separately reported);
3. Wife Stated patient saw or
Ophthalmologist for eye issue Category 3: Discussion of management or test interpretation
4. Spoke with Ophthalmologist
patient has mild retinopathy •Discussion of management or test interpretation with
external physician/other QHP/appropriate source (not
Data – High separately reported)
Complexity
Risk of Complication and/or Morbidity or Mortality of Patient MGT
Definition of Risk
Risk of Complication and/or Morbidity or Mortality of Patient MGT

• Counseling
• Diet and Exercise
• EKGs and EEGs
• Rest
• Superficial bandages and
Minimal - dressings
• Urinalysis
Risk • Ultrasounds, Echocardiogram

Risk factors are those that are relevant to the patient and procedure.
Risk of Complication and/or Morbidity or Mortality of Patient MGT

 Chest x-rays,
 CT/MRI w/o contrast
 IV fluids w/o additives
 Lab tests requiring
Low - Risk venipuncture
 Minor surgery w/o risk factors
 Over the counter drugs
 Therapies (PT/OT, etc.)

Risk factors are those that are relevant to the patient and procedure.
Risk of Complication and/or Morbidity or Mortality of Patient MGT

•Prescription drug management


•Decision regarding minor surgery w/
identified patient or procedure risk
factors
•Decision regarding elective major
surgery w/o identified patient or
Moderate - procedure risk factors
Risk •Diagnosis or treatment significantly
limited by social determinants of health

Risk factors are those that are relevant to the patient and procedure.
Risk of Complication and/or Morbidity or Mortality of Patient MGT

Examples of SDH Codes


Z56.3 Stressful work schedule
Z55.0 Illiteracy and low‐level literacy
Z57.6 Occupational exposure to extreme temperature
Z59.0 Homelessness
Z59.4 Lack of adequate food and safe drinking water
Z59.5 Extreme poverty
Z59.7 Insufficient social insurance and welfare support
Z60.2 Problems related to living alone
Z62.21 Child in welfare custody
Z63.31 Absence of family member due to military
deployment
Z64.0 Problems related to unwanted pregnancy
Z65.2 Problems related to release from prison
Risk of Complication and/or Morbidity or Mortality of Patient MGT

•Drug therapy requiring intensive monitoring for


toxicity
•Decision regarding elective major surgery w/
identified patient or procedure risk factors
•Decision regarding emergency major surgery
•Decision regarding hospitalization or escalation
High - Risk of hospital level care
•Decision not to resuscitate or to deescalate
care because of poor prognosis

Risk factors are those that are relevant to the patient and procedure.
Drug Therapy with Intensive Monitoring for Toxicity

A therapeutic agent which has the potential to cause serious morbidity or death

Monitoring is performed for assessment of potential adverse effects, not primarily


for assessment of the therapeutic effect

Monitoring should follow practice that is generally accepted for the drug but may
be patient specific in some cases.

Intensive monitoring may be long-term or short term. Long-term intensive


monitoring is performed not less than quarterly.

Monitoring may include a lab test, a physiologic test or imaging

• Monitoring by history or examination does not qualify. The monitoring


affects the level of medical decision making in a visit in which it is
considered in the management of the patient.
Risk of Complication and/or Morbidity or Mortality of Patient MGT

If a provider considers a
treatment but chooses to
The 2021 guidelines make it Patient non-compliance not select that treatment,
clear that options (Z91.19) may add to risk, documentation should
considered, but not providers should document support the reason why,
selected. how. such as patient refusal,
patient is not a surgical
candidate, etc.
And
And /or
/or
Auditing Based on Time

Time is based on the total


time (both face-to-face and non-face-to-face) personally spent by the
physician or NPP on E/M services on the date of the encounter.

• Start and stop times are not required to be documented.


• Providers should not list a range of time. When using time to level an
• CPT® : “The appropriate time should be documented in the medical record when E/M, the time statement must
it is used as the basis for code selection.” be documented by provider
• If time is not documented, or is an insufficient time for the minimum code, within the note and must state
MDM must be used to level the encounter. their best estimate of the exact
time spent in care of the patient
on the date of the encounter.
Shared or Split Visit Time

Add time spent by reporting provider who is


assessing and managing patient.
Only distinct time should be summed.
When two or more individuals jointly meet with
or discuss the patient, only the time of one
individual should be counted.
Total Time Activities
Physician or other qualified health care professional time includes the following activities, when
performed:
 preparing to see the patient (eg, review of tests)
 obtaining and/or reviewing separately obtained history
 performing a medically appropriate examination and/or evaluation
 counseling and educating the patient/family/caregiver
 ordering medications, tests, or procedures
 referring and communicating with other health care professionals (when not separately reported)
 documenting clinical information in the electronic or other health record
 independently interpreting results (not separately reported) and communicating results to
the patient/family/caregiver
 care coordination (not separately reported)◄

Do not count time spent on the following:


 The performance of other services that are reported separately
 Travel
 Teaching that is general and not limited to discussion that is required for the management of a
specific patient
Time
Time Activities
Provider Activities Time Spent (Minutes)
Pre-Visit
Preparing to see the patient (e.g., review of tests, reviewing notes, 2
results, correspondence, reports) (Note sources, dates)
Visit
Obtaining and/or reviewing separately obtained history (Note sources) 2
Performing a medically appropriate examination and/or evaluation 5
Counseling and educating the patient/family/caregiver 1
Referring and communicating with other health care professionals (when
not separately reported)
Post-Visit
Documenting clinical information in the electronic or other health record 5
Independent interpretation of tests (not separately billed) and
communicating results to the patient/ family/caregiver
Care Coordination (not separately billed)
TOTAL TIME ON DOS 15
Time Based Coding
Time Calculation
AMA Time Calculation
Established
New Patient Patient

15 m inutes
99202 99212 If < M
15-29 mins 10-19 mins use MD

99203 99213
30-44 mins 20-29 mins

99204 99214
45-59 mins 30-39 mins

99205 99215
60-74 mins 40-54 mins
Prolonged Services
h a n ges
C
2023 ming CMS
Co

CPT® 99417 NEW CPT® 993X0 G2212

Prolonged office or other Prolonged IP or Prolonged office or other


OP E/M service(s) observation E/M OP E/M service(s)
Each 15 min of total time service(s) Beyond each additional
(List separately in Each 15 minutes of total 15 min of total time (List
addition to codes 99205, time (List separately in separately in addition to
99215,99245, addition to the code (Use CPT® codes 99205, 99215
99345,99350, 99483) 993X0 in conjunction for office or other
with99223,99233,99236, outpatient E/M)
99255,99306, 99310) Proposing 3 new
prolonged HCPCS codes.
Prolonged Services – CMS & AMA
Use code 99417 to report prolonged total time provided by the physician or QHP on the date of an office or other
outpatient services, office consultation, or other outpatient (home, residence) E/M service, contact beyond the
required time of the primary service when the primary service level has been selected using total time, each 15
minutes of total:
Additional CPT notes with 99417:
list separately in addition to CPT® codes (Use 99417 in conjunction with 99205, 99215, 99245, 99345, 99350,
99483)
Do not report 99417 for any time unit less than 15 min
Do not report 99417 on the same date of service as 90833, 90836, 90838, 99358,99359, 99415, 99416.
For prolonged services on a date other than the date of a face-to-face evaluation and management encounter
with the patient and/or family/caregiver, see 99358, 99359.

Total time is the sum of all time, with and without direct patient contact and including prolonged
time, spent by the reporting practitioner on the date of service of the visit.

99417 may not be used with psychotherapy


services.
Prolonged Services
Prolonged Services

Use code 993X0 to report prolonged total time provided by the physician or GXXX3
QHP on the date of an inpatient (Nursing Facility, Observation or IP Consultation) E/M service, contact
beyond the required time of the primary service when the primary service level has been selected using
total time, each 15 minutes of total:
list separately in addition to CPT® codes 99223, 99233, 99236, 99255, 99306, 99310
Do not report 993X0 for any time unit less than 15 min
Do not report 993X0 on the same date of service as 90833, 90836, 90838, 99358, 99359)
For prolonged services on a date other than the date of a face-to-face evaluation and
management encounter with the patient and/or family/caregiver, see 99358, 99359.

*
Total time is the sum of all time, with and without direct patient contact and
including prolonged time, spent by the reporting practitioner on the date of
service of the visit.
Prolonged Services – 99358 & 99359 Codes
Total Duration of Prolonged Code(s)
Code(s) Services without Codes 99358 and 99359 are used when a
direct face-to-face Contact
prolonged service in relation to a face-to-face
Less than 30 minutes Not reported separately evaluation and management encounter with the
30-74 minutes 99358 X 1 patient and/or family/caregiver is provided on a
75-104 minutes 99358 X 1 and 99359 x 1 date other than the date of the E/M, whether
105 or more minutes 99358 x 1 and 99358 x 2 or time was used to select the level of the face-to-
more for each additional 30 face service.
minutes

Code Description  Prolonged service without direct patient contact may only
be reported when it occurs on a date other than the date
99358 Prolonged evaluation and management
service before and/or after direct patient of the evaluation and management service.
care; first hour  For example, extensive record review may relate to a
previous evaluation and management service performed
+99359 Prolonged evaluation and management at an earlier date.
service before and/or after direct patient  However, it must relate to a service or patient which (face-
care; each additional 30 minutes. to-face) patient care has occurred or will occur and relate
to ongoing patient management.
Prolonged Services

99354, 99355 have been deleted.

•For prolonged evaluation and management services on the date of an


outpatient service, home or residence service, or cognitive assessment
and care plan, use 99417.

99356, 99357 have been deleted.

•For prolonged evaluation and management services on the date of


an inpatient or observation or nursing facility service, use 993X0, a
new code to be released during the official CPT® update.
Prolonged Service – Clinical Staff
• Codes 99415, 99416 are used when an evaluation and management (E/M) service is provided in the office or
outpatient setting that involves prolonged clinical staff face-to-face time with the patient and/or
family/caregiver.
• The physician or other QHP is present to provide direct supervision of the clinical staff. This service is reported in
addition to the designated E/M services and any other services provided at the same session as E/M services.
• Time spent performing separately reported services other than the E/M service is not counted toward the
prolonged services time.
• Codes 99415, 99416 may be reported for no more than two simultaneous patients and the time reported is
the time devoted only to a single patient.
• Prolonged clinical staff service (the service beyond the highest time in the range of total time of the service)
during an evaluation and management service in the office or outpatient setting, direct patient contact with
physician supervision.

Code Description
99415 First hour
+99416 each additional 30 minutes
Prolonged Service – Clinical Staff

The starting point for 99415 is 30 minutes beyond the typical clinical staff time for ongoing assessment of
the patient during the office visit. The Reporting Prolonged Clinical Staff Timetable provides the typical
clinical staff times for the office or other outpatient primary codes, the range of time beyond the clinical
staff time for which 99415 may be reported, and the starting point at which 99416 may be reported.
Place of Service – Initial Hospital OR Observation

 The following codes are used to report the first hospital inpatient (21) or observation (22)
status encounter with the patient.
 Initial hospital inpatient or observation care, per day, for the evaluation and management
of a patient, which requires a medically appropriate history and/or examination and MDM

Initial History & Exam MDM Time*


99221 Medical Appropriate History and/or Straightforward or Low 40
examination

99222 Medical Appropriate History and/or Moderate 55


examination

99223 Medical Appropriate History and/or High 75


examination
993X0     90+

Prolonged (993X0) 90 minutes or longer


Place of Service – Subsequent Hospital OR Observation
• The following codes are used to report the subsequent hospital (21) inpatient or
observation (22) status encounter with the patient.
• Subsequent hospital inpatient or observation care, per day, for the evaluation and
management of a patient, which requires a medically appropriate history and/or
examination and MDM

Subsequent History & Exam MDM Time*

99231 Medical Appropriate History and/or Straightforward or Low 25


examination
99232 Medical Appropriate History and/or Moderate 35
examination
99233 Medical Appropriate History and/or High 50
examination
993X0     65+

Prolonged (993X0) 65 minutes or longer


Place of Service – Initial & Subsequent Observation
Hospital Observation Services have been deleted.
Place of Service – Same day admit & Discharge
• For a patient admitted and discharged from hospital inpatient (21) or observation (22) status on
the same date, for the evaluation and management of a patient including admission and
discharge on the same date, which requires a medically appropriate history and/or examination
and MDM.
• Two separate entries are required to document the admission and subsequent discharge including
the final examination of the patient, discussion of the hospital stay, instructions for continuing care
to all relevant caregivers, and preparation of discharge records, prescriptions, and referral forms.

Same Day
Admit/DC History & Exam MDM Time*

Medical Appropriate History and/or


99234 Straightforward or Low 45
examination
Medical Appropriate History and/or
99235 examination Moderate 70

Medical Appropriate History and/or


99236 High 85
examination
993X0     100+
Discharge Codes

• The hospital inpatient (21) and observation (22) discharge day management codes are
used to report the total time (does not need to be continuous) spent by the physician or
QHP who is responsible for discharge services, on the day of the final discharge of the
patient.
• The codes include, as appropriate, final examination of the patient, discussion of the
hospital stay, instructions for continuing care to all relevant caregivers, and preparation of
discharge records, prescriptions, and referral forms.

Discharge Documentation Time

Final examination, discussion hospital stay,


99238 instructions for continuing care, preparation of 30 minutes or less
discharge records, RX and referrals

Final examination, discussion hospital stay,


99239 instructions for continuing care, preparation of More than 30 minutes
discharge records, RX and referrals
Place of Service - Consultation

Consultation service require a request from Request


another physician or QHP to recommend care
for a specific condition or problem.
The consulting provider’s opinion and any
Recommendation
services that were ordered or performed must
be communicated in written report to the
requesting physician or QHP.
Report
Outpatient Consultation Codes
The following codes may be used to report consultations that are provided in the office
(11) or other outpatient site (19/22), including the home or residence (12/13), or
emergency department (23).

Outpatient History & Exam MDM Time*

99242 Medical Appropriate History and/or Straightforward 20


examination
99243 Medical Appropriate History and/or Low 30
examination
99244 Medical Appropriate History and/or Moderate 40
examination
Medical Appropriate History and/or
99245 examination High 55
99417     70+
Medicare does
NOT cover
consultations
Inpatient Consultation Codes
The following codes should be used to report consultations reported in hospital inpatients (21), observation-
level patients (22), residents of nursing facilities (31/32), or patients in a partial hospital setting, and when the
patient has not received any face-to-face professional services from the physician or other QHP or another
physician or other QHP of the exact same specialty and subspecialty who belongs to the same group practice
during the stay.

If a consultation is performed in anticipation of, or related to, an admission by another physician or other QHP, and
then the same consultant performs an encounter once the patient is admitted by the other physician or other QHP,
report the consultant’s inpatient encounter with the appropriate subsequent care code (99231, 99232, 99233).

Inpatient History & Exam MDM Time*


Medical Appropriate History and/or
99252 Straightforward 35
examination
Medical Appropriate History and/or
99253 examination Low 45

Medical Appropriate History and/or


99254 Moderate 60
examination
Medical Appropriate History and/or
99255 examination High 80
993X0     95+
Emergency Department Codes
• An emergency department (23) is defined as an organized hospital-based facility for
the provision of unscheduled episodic services to patients who present for
immediate medical attention. The facility must be available 24 hours a day.
• Time is not a descriptive component for the emergency department levels of E/M
services because emergency department services are typically provided on a
variable intensity basis, often involving multiple encounters with several patients
over an extended period of time.
• May be used by physicians and QHPs other than just the ED staff.
ED History & Exam MDM
Evaluation and management of a patient that may not
99281 require the presence of a physician or other qualified _
healthcare provider
99282 Medical Appropriate History and/or examination Straightforward
99283 Medical Appropriate History and/or examination Low
99284 Medical Appropriate History and/or examination Moderate
99285 Medical Appropriate History and/or examination High
Incident to & Split & Shared Services

99211 (Office and other Incident-To guidelines


Outpatient) does not require May not require the
presence of the physician or apply there must be an order for
 MDM level other QHP, but the service is the service, and the supervising
 Total time spent provided under the physician’s physician or NPP (or one from
 Presenting problem(s) no or other QHP’s supervision. the same group) must be within
requirement the office suite and immediately
available if needed.

99281 (Emergency May not require the Split/Shared Visit a visit in


Department) does not require presence of the physician or which a physician and other
 MDM level other QHP, but the service is QHP(s) jointly provide the
 Total time spent provided under the physician’s face-to-face and non-face-to-
 Presenting problem(s) no or other QHP’s supervision. face work related to the visit.
requirement
Initial Nursing Facility Care

NEW HIGH PROBLEM:

Multiple morbidities requiring intensive management

• A set of conditions, syndromes, or functional impairments that are likely


to require frequent medication changes or other treatment changes
and/or re-evaluations. The patient is at significant risk of worsening
medical (including behavioral) status and risk for (re)admission to a
hospital.
Initial Nursing Facility Care

• These codes should also be used to report evaluation and management services
provided to a patient in nursing facilities (32), skill nursing facilities (31), a
psychiatric residential treatment center (56) and immediate care facility for
individuals with intellectual disabilities (54).
• Regulations pertaining to the care of nursing facility residents govern the nature
and minimum frequency of assessments and visits. These regulations also
govern who may perform the initial comprehensive visit.
• Modifiers may be required to identify the principal physician from specialist
performing consultations or concurrent care.
Initial History & Exam MDM Time*
Medical Appropriate History and/or
99304 examination Straightforward or Low 35

99305 Medical Appropriate History and/or Moderate 45


examination
99306 Medical Appropriate History and/or High 60
examination
993X0 _ _ 60+
Subsequent Nursing Facility Care
• The following codes are used to report the subsequent nursing facilities and
skilled nursing facilities encounter with the patient.
• Subsequent nursing facility care, per day, for the evaluation and
management of a patient, which requires a medically appropriate history
and/or examination
• Use subsequent visit when the principal physician’s team member performs
Subsequent
care before the required History & Exam
comprehensive assessment. MDM Time*
Medical Appropriate History and/or
99307 Straightforward 10
examination
Medical Appropriate History and/or
99308 examination Low 15

99309 Medical Appropriate History and/or Moderate 30


examination
99310 Medical Appropriate History and/or High 45
examination
993X0 _ _ 60+
(99318 Annual NF Assessment has been deleted. To report, see 99307, 99308,
99309, 99310)
Discharge Codes - Nursing Facility Care
• The nursing facility discharge management codes are to be used to report the
total duration of time spent by a physician or other QHP for the final nursing
facility discharge of a patient
• The codes include, as appropriate, final examination of the patient, discussion of
the hospital stay, instructions for continuing care to all relevant caregivers, and
preparation of discharge records, prescriptions, and referral forms.
• These services require a face-to-face encounter with the patient and/or
family/caregiver that may be performed on a date prior to the date the patient
leaves the facility. Code selection is based on the total time on the date of the
discharge management face-to-face encounter
New Patient – Home or Residence Service
• The following codes are used to report evaluation and management services provided in
a home or residence (12) to a new patient, which requires a medically appropriate
history and/or examination MDM.
• Home may be defined as a private residence, temporary lodging, or short-term
accommodation (e.g., hotel, campground, hostel, or cruise ship). These codes are also
used when the residence is an assisted living facility (13), group home (14) (that is not
licensed as an intermediate care facility for individuals with intellectual disabilities),
custodial care facility (33) or residential substance abuse treatment facility (55).
• 99324, 99325, 99326, 99327, 99328 have been deleted.
Code Description Time
99341 MDM of straightforward complexity 15
99342 MDM of low complexity 30
99344 MDM of moderate complexity 60
99345 MDM of high complexity 75

Prolonged (99417) 90 minutes or longer


Established Patient - Home or Residence Service

 The following codes are used to report evaluation and management services
provided in a home or residence to an established patient.
 (99334, 99335, 99336, 99337 have been deleted. For domiciliary, rest home [eg,
boarding home], or custodial care services, established patient, see home or
residence services codes 99347, 99348, 99349, 99350)
These codes are also used when the residence is an assisted living facility (13), group
home (14) (that is not licensed as an intermediate care facility for individuals with
intellectual disabilities), custodial care facility (33), or residential substance abuse
treatment facility (55).
Code Description Time
99347 MDM of straightforward complexity 20
99348 MDM of low complexity 30
99349 MDM of moderate complexity 40
99350 MDM of high complexity 60
Prolonged (99417) 75 minutes or longer
References
 
• AMA E/M 2023:
• https://onlinexperiences.com/scripts/Server.nxp?LASCmd=AI:1;F:LBSATTACH!V&AttachmentKey=8655664
• CPT® Evaluation and Management (E/M) Code and Guideline Changes https://www.ama-assn.org/system/files/2023-e-m-descriptors-guidelines.pdf
• New office and other Outpatient 2021 MDM Table https://www.ama-assn.org/system/files/2019-06/cpt-revised-mdm-grid.pdf
• AMA Guide for 2021 E/M Changes https://www.ama-assn.org/system/files/2019-06/cpt-office-prolonged-svs-code-changes.pdf https://
www.cms.gov/newsroom/fact-sheets/final-policy-payment-and-quality-provisions-changes-medicare-physician-fee-schedule-calendar-year-1
• CMS E/M Services Guide https://www.cms.gov/outreach-and-
education/medicare-learning-network-mln/mlnproducts/downloads/eval-mgmt-serv-guide-icn006764.pdf
• MLN on Final Rules
https://www.cms.gov/Outreach-and-Education/Outreach/NPC/Downloads/2019-11-06-ASC-Presentation.pdf https://
www.cms.gov/files/document/12120-pfs-final-rule.pdf
• https://www.cms.gov/newsroom/fact-sheets/proposed-policy-payment-and-quality-provisions-changes-medicare-physician-fee-schedule-calendar-year-2
• Medicare Claims Processing Manual Ch 12 https://www.cms.gov/Regulations-and-
guidance/GuidancE/Manuals/Downloads/clm104c12.pdf

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