Neurology & Pain Management Coding Alert

Did you know that other E/M code sets will get overhauls like 99202-99215?

If you thought 2021 was an action-packed year in terms of adjusting to new rules for evaluation and management (E/M) services, just wait.

Given what’s scheduled to occur — and what’s already happened this year with office/ outpatient E/Ms — you’re in for an interesting couple of years on the E/M coding front. That’s the impression Lynn M. Anderanin, CPC, CPMA, CPPM, CPC-I, COSC, gave during her presentation at HEALTHCON Regional 2021 in Charleston, South Carolina.

During the session, Anderanin described how the 2021 E/M changes are affecting coders, and gave attendees a heads-up about what’s going down at the AMA for 2022 and beyond.

The Present: Office/Outpatient E/Ms

Anderanin first spoke about how coders and providers are adjusting to the new descriptors for office/outpatient codes 99202 (Office or other outpatient visit for the evaluation and management of a new patient, which requires a medically appropriate history and/ or examination and straightforward medical decision making. When using time for code selection, 15-29 minutes of total time is spent on the date of the encounter.) through 99215 (Office or other outpatient visit for the evaluation and management of an established patient, which requires a medically appropriate history and/or examination and high level of medical decision making. When using time for code selection, 40-54 minutes of total time is spent on the date of the encounter.).

This year, coders started using time or medical decision making (MDM) as the sole deciding factor when choosing an E/M code. This has created a need for coders to reexamine their MDM and time coding, as they’re the only components you can rely on to make an informed decision on the 99202-99215 codes.

When counting up time on an office/outpatient E/M code, Anderanin says you should ask yourself the following questions before filing:

• “Is everything being counted?”
• “Does the documentation support the visit?”
• “Are the appointment schedules proportionate to the visits?”
• “How often are you using +99417 [Prolonged office or other outpatient evaluation and management service(s) beyond the minimum required time of the primary procedure which has been selected using total time, requiring total time with or without direct patient contact beyond the usual service, on the date of the primary service, each 15 minutes of total time (List separately in addition to codes 99205, 99215 for office or other outpatient Evaluation and Management services)] and G2211 [Visit complexity inherent to evaluation and management associated with medical care services that serve as the continuing focal point for all needed health care services and/or with medical care services that are part of ongoing care related to a patient’s single, serious condition or a complex condition. (add-on code, list separately in addition to office/outpatient evaluation and management visit, new or established)]?”

As for office/outpatient E/Ms that you code based on MDM, Anderanin says you should make sure that the practice has:

• Updated templates that reflect the new code descriptors.
• Policies in place on how the practice addresses MDM questions and how it interprets risk.
• Buy-in from all your providers on the new E/M rules; coding will suffer — and auditors will notice — if you’re coding for providers you can’t convince to use the time/MDM rules.
• Safeguards in place against the elimination of encounter data that might be used to prove MDM.

The Future: More Big E/M Changes

Evaluation and management (E/M) service code revisions will go big in 2023 — when an anticipated explosion of change occurs in the E/M section of the CPT® manual. “The AMA has said that this is in the proposed schedule … to take effect January 2023,” Anderanin said of the E/M changes.

According to Anderanin’s reading of the AMA proposal, the expected changes include:

• Deletion of observation codes 99217 (Observation care discharge day management…) through 99226 (Subsequent observation care, per day, for the evaluation and management of a patient, which requires at least 2 of these 3 key components: A detailed interval history; A detailed examination; Medical decision making of high complexity.)
• Revision of 99221 (Initial hospital care, per day, for the evaluation and management of a patient, which requires these 3 key components: A detailed or comprehensive history; A detailed or comprehensive examination; and Medical decision making that is straightforward or of low complexity.) through 99239 (Hospital discharge day management; more than 30 minutes to include observation and revisions to the guidelines)
• Deletion of consultation codes 99241 (Office consultation for a new or established patient, which requires these 3 key components: A problem focused history; A problem focused examination; and Straightforward medical decision making.) and 99251 (Inpatient consultation for a new or established patient, which requires these 3 key components: A problem focused history; A problem focused examination; and Straightforward medical decision making.), “with revisions to the [consultation] guidelines,” said Anderanin. “Surprisingly, they’re not planning to delete consultation codes entirely; but they do plan on eliminating the level 1s [99241, 99251].”
• Revisions of the guidelines for emergency department (ED), nursing facilities, and prolonged services.

Stay tuned: Nothing is set in stone for E/M changes in 2023 — but you can bet that big news is coming. Look for more information on potential 2023 E/M changes in future issues of Neurology & Pain Management Coding Alert.