Wouldn't that 99214 example fall under 99213 under current rules (2 pts for Est. problem worsening and moderate under risk) if not factoring history and exam?Well, it's not up to the coders to say what 'seems pretty steep' or not. We don't make the rules, we just apply them.
In any case, it really isn't a big change. A visit for a patient with worsening acne with prescription drug management could likely involve a detailed history and/or exam, which could be coded as 99214 under the current rules too. I'd note too that Appendix C of CPT includes visits for treatment of acne in clinical examples for both 99213 and 99214 visits:
Office visit for a 13-year-old, established patient, with comedopapular acne of the face which has shown poor response to topical medication. Discussion of use of systemic medication.
Follow-up visit for a 15-year-old withdrawn patient with four-year history of papulocystic acne of the face, chest, and back with early scarring and poor response to past treatment. Discussion of use of systemic medication.
But you do have to factor in history and exam (and also any data points or other factors that may be applicable) under current rules.Wouldn't that 99214 example fall under 99213 under current rules (2 pts for Est. problem worsening and moderate under risk) if not factoring history and exam?