Podiatry Coding & Billing Alert

Never report online digital E/M services for cumulative service time that is less than five minutes.

In the article “Adopt Online Digital, Virtual QNHP, and RPM E/M codes Before Jan. 1,” found in Podiatry Coding and Billing Alert vol. 11, no. 11, you learned all about the new online digital 2020 evaluation and management (E/M) codes 99421 (Online digital evaluation and management service, for an established patient, for up to 7 days, cumulative time during the 7 days; 5-10 minutes) through 99423 (… 21 or more minutes).

Read more to learn about the new CPT^® guidelines you’ll get to go along with these new E/M codes.

Follow These Rules for 99241-99423

CPT^® defines 99241-99423 as “patient-initiated services with physicians or other qualified health care professionals (QHPs).” You should heed the following rules when reporting these services:

• Rule 1: Online digital E/M services require a physician or other QHP’s evaluation, assessment, and management of the patient. You should not report 99421-99423 for “the nonevaluative electronic communication of test results, scheduling of appointments, or other communication that does not include E/M,” per CPT^®.
• Rule 2: Patients should use Health Insurance Portability and Accountability Act (HIPAA)-compliant platforms to initiate online digital E/M services. Examples of such platforms include electronic health record (EHR) portals, secure email, and other digital applications.
• Rule 3: Although the patient must be established to appropriately report 99421-99423, the patient’s problem can be new to the physician or other QHP.
• Rule 4: The physician or other QHP must permanently store the documen­tation from all online digital E/M encounters. The documentation can be either an electronic or hard copy. 
• Rule 5: You should not calculate clinical staff time as part of cumulative time for 99421-99423.
• Rule 6: Never report online digital E/M services for cumulative service time that is less than five minutes.

Don’t Report 99421-99423 With These Codes

When you report 99421-99423, you must understand which codes you cannot report in conjunction with these online digital codes. For example, never report 99421-99423 on a day when the physician or other QHP reports new patient office or other outpatient service codes 99201-99205; established patient office or other outpatient codes 99212-99215; and new or established patient office or other outpatient consultation codes 99241-99245.

Additionally, you should never report 99421-99423 when you use digitally stored data and remote physiologic monitoring code 99091; domiciliary, rest home, or home care plan oversight codes 99339 and 99340; care plan oversight codes 99374-99380; or transitional care codes 99495 and 99496 for the same communications.

Lastly, you should never report 99421-99423 for home and outpatient international normalized ratio (INR) monitoring when reporting home and outpatient INR monitoring codes 93792 and 93793.

Discover Cumulative Service Time Components

When they perform 99421-99423 services, the physician’s or other QHP’s cumulative service time includes multiple components, according to CPT^®. They are as follows:

• Reviewing the patient’s initial inquiry, which is when the seven-day period begins.
• Reviewing the patient’s records or reviewing data relevant to assessing the patient’s problem.
• Personal physician or other QHP interaction with the clinical staff that focuses on the patient’s problem.
• Developing management plans, which includes when the physician or other QHP generates prescriptions or orders tests.
• Any subsequent communication with the patient through online, telephone, email, or other digitally supported communications, which “does not otherwise represent a separately reported E/M service.”

Important: “All professional decision making, assessment, and subsequent management by physicians or other QHPs in the same group practice contribute to the cumulative service time of the patient’s online digital E/M service,” per CPT^®.

Dig Into 7-Day Period Rules With 5 Tips

You should report online digital E/M services once for the physician’s or other QHP’s cumulative time they devote to the online digital service over a seven-day period, according to CPT^®. Heed the following tips to make sure you understand how to correctly report codes during this seven-day period.

Tip 1: If a separately reported E/M visit occurs within seven days of the online digital service’s initiation, then the work the physician or QHP devotes to the online digital E/M service should be incorporated into the separately reported E/M visit, per CPT^®. This includes any E/M visit and procedures the physician or QHP provides through synchronous telemedicine using interactive audio and video telecommunication equipment.

Tip 2: If a patient initiates an online digital inquiry for the same or a related problem within seven days of a previous E/M service, you shouldn’t report the online digital visit. Also, if the online digital inquiry is

“related to a surgical procedure and occurs during the postoperative period of a previously completed procedure,” you should not separately report the online digital E/M service, according to CPT^®.

Tip 3: On the other hand, if the patient generates “the initial online digital inquiry for a new problem within seven days of a previous E/M visit that addressed a different problem,” you can separately report the online digital E/M service.

Tip 4: And, if the patient presents a new, unrelated problem during the online digital service’s seven-day period, then you should add the time the physician or other QHP spent on evaluating, assessing, and managing the additional problem to the cumulative service time of the online digital E/M service.