Question What element level of MDM would a specialist referral fall under 2021 E/M Guidelines?


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Our PCP providers would like to consider a referral to a specialist as a LOW RISK under column 3 of the 2021 E/M table for Risk of Complications and/or Morbidity or Mortality of Patient Management. In comparison to Box A. of the 2020 & earlier E/M table and guidelines, whether a condition was established and worsening (2 pts.), or was new and required additional work up (4 pts.), the diagnosis itself would be considered at minimum of low complexity. The guidance from this section originally indicated: "Need to seek advice from others is another indicator of complexity of diagnostic or management problems"
So my question is this: If the PCP provider documents the conditions as worsening or new requiring additional work-up outside the scope of said practice, and documents a referral to a specialist for additional treatment, according to the 2021 E/M Table, would you consider this a Low level of MDM based on column 1 (# and complexity of problems addressed) and column 3 (risk of complication and/or morbidity or mortality of patient management)?

Appreciate the feedback and any links available indicating where referrals fall under the 2021 E/M Guidelines.

Shannon Lindloff, CPC, CRC
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I have this exact same question, Shannon. I haven't been able to find the best "placement" for a referral on the MDM table.
Today in the new Healthcare Business Monthly for Nov 2021 I read that a referral does not count as data, but does count as care coordination in response to someone asking if referrals count towards care coordination. They specially noted that it doesn't count as data but did not say anything about the other 2 elements.

We currently count referrals as Low risk, with the possibility of being counted as a moderate risk should urgency/increased risk play a factor.
Often times I find when the providers are making a referral outside of their scope of practice for treatment, the risk of the patient's condition worsening/continuing becomes a factor.

would love other's input on this as well!!!