Ob-Gyn Coding Alert

E/M:

Apply New MDM, Time Rules to Your 2023 Inpatient and Observation Coding

Remove 99217 and others from your coding toolbox.

By now you know that Jan. 1, 2023 is going to bring another round of evaluation and management (E/M) coding changes reminiscent of the 2021 changes to your office and other outpatient coding. The 2023 changes will include updates to your inpatient and hospital observation coding — namely, you’ll need to throw your old way of coding observation out the window.

Here’s what you need to know to keep your ob-gyn’s hospital service reimbursement flowing in the new year.

Erase These Observation Care Codes

Effective Jan. 1, 2023, you will no longer be able to report 99218-99220 (Initial observation care, per day, for the evaluation and management of a patient …), which you currently use to report initial outpatient hospital observation services; 99224-99226 (Subsequent observation care, per day, for the evaluation and management of a patient …), which you currently use to report subsequent outpatient hospital observation services; or 99217 (Observation care discharge day management …), which you currently use to report “all services provided to a patient on discharge from outpatient hospital ‘observation status’ if the discharge is on other than the initial date of ‘observation status’” per the soon-to-be-deleted codes and their descriptors.

Report 99221-99236 for Observation or Inpatient in 2023

Instead, you will use one of the following existing hospital care codes from 99221-99223 (Initial hospital care …), 99231-99233 (Subsequent hospital care …), or 99234-99236 (Observation or inpatient hospital care … including admission and discharge on the same date …). However, you’ll need to pay attention because each of these codes has extensive descriptor revisions for 2023, starting with the beginning of the descriptors as follows:

  • 99221-99223 (Initial hospital care changes to Initial hospital inpatient or observation care …)
  • 99231-99233 (Subsequent hospital care changes to Subsequent hospital inpatient or observation care … )
  • 99234-99236 (Observation or inpatient hospital care … including admission and discharge on the same date changes to Hospital inpatient or observation care … including admission and discharge on the same date … )

The revised code descriptors all follow a similar pattern. As an example, compare the descriptors for the 2022 and 2023 versions of level one subsequent hospital inpatient care code 99231. Notice that unlike the 2022 code, the 2023 descriptor specifies that the code applies to observation care:

  • 2022: 99231 (Subsequent hospital care, per day, for the evaluation and management of a patient, which requires at least 2 of these 3 key components: A problem focused interval history; A problem focused examination; Medical decision making that is straightforward or of low complexity. Counseling and/or coordination of care with other physicians, other qualified health care professionals, or agencies are provided consistent with the nature of the problem(s) and the patient’s and/or family’s needs. Usually, the patient is stable, recovering or improving. Typically, 15 minutes are spent at the bedside and on the patient’s hospital floor or unit.)
  • 2023: 99231 (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 straightforward or low level of medical decision making. When using total time on the date of the encounter for code selection, 25 minutes must be met or exceeded.)

Table 1 reveals how the medical decision making (MDM) level and total times vary based on the code.

Get an Overview of What’s New

Just as they did for the 2021 office/outpatient E/M changes, “the CPT® Editorial Panel worked to, again, create revisions to the E/M code descriptors and guidelines that met their objective to decrease the administrative burden of excessive documentation whenever possible,” says Mary I. Falbo, MBA, CPC, CEO of Millennium Healthcare Consulting Inc. in Lansdale, Pennsylvania.

Old way: The 2022 hospital inpatient codes require you to consider the three key components of history, exam, and MDM. Alternatively, you can code based on time when counseling and/or coordination of care takes up more than 50 percent of the floor or unit time in the hospital setting. CPT® 2022 guidelines define unit/floor time as “the time present on the patient’s hospital unit and at the bedside rendering services for that patient. This includes the time to establish and/or review the patient’s chart, examine the patient, write notes, and communicate with other professionals and the patient’s family.”

New way: Selecting the correct 2023 hospital inpatient code is based either on MDM or total time. While a medically appropriate history and/or exam is part of the service and should be documented when performed, those factors don’t influence inpatient E/M code choice in 2023.

Total time includes both face-to-face time and non-face-to-face time the ob-gyn spends on the encounter. “CPT® also indicated that these time parameters include time on or off the inpatient unit,” says Leah Fuller, CPC, COC, senior consultant, Pinnacle Enterprise Risk Consulting Services, in Charlotte, North Carolina. Of course, you should not include time spent on separately reported services.

CPT® 2023 also includes a rule stating: “When using MDM or total time for code selection, a continuous service that spans the transition of two calendar dates is a single service and is reported on one calendar date. If the service is continuous before and through midnight, all the time may be applied to the reported date of the service.”

Know the Definitions of Initial and Subsequent

In 2023, you’ll report initial service codes 99221-99223 for the first hospital inpatient or observation status encounter with the patient. The codes apply when “the patient has not received any professional services from the physician or other qualified health care professional [QHP] or another physician or other qualified health care professional of the exact same specialty and subspecialty who belongs to the same group practice” during the stay, per CPT® E/M guidelines.

If the patient has received professional (face-to-face) services during the stay from the physician or other QHP (or a physician or QHP of the exact same specialty and subspecialty and in the same practice), then you’ll use subsequent service codes 99231-99233.

Note: CPT® 2023 also makes changes to E/M codes for consultations, emergency department (ED) services, nursing facility services, home or residence services, prolonged services, and admission and discharge services on the same date. Be sure to review the updated codes and guidelines for the services that are relevant to your practice.