I am aware of the "3 year" rule for E&M decision making. I was told by my instructor in school that if a patient switches to another insurance company( Blue Cross to UHC) that we can report 99202, 99203 etc. I have a patient that was recently in an accident, and she has been treating with us. We are now submitting to her Med Pay. I billed this as an established patient visit because I haven't seen anything in E&M guidelines that supports what my teacher said. I was wondering if anyone could shed some light on this for me? Thanks so much!!