99202-99215: Office/Outpatient E/M Coding in 2021

Healthcare professionals across a wide range of specialties report evaluation and management (E/M) CPT^® codes on insurance claims to request reimbursement for services performed in the office or other outpatient setting.

The American Medical Association (AMA), which holds copyright in CPT^®, and the Centers for Medicare & Medicaid Services (CMS) implemented major revisions related to office and outpatient E/M codes 99201-99215 in 2021. One goal of these changes was to streamline the coding and documentation requirements for these commonly reported codes.

Note: This article is specific to 2021 changes. There were additional significant E/M changes in 2023.

Office/Outpatient E/M Coding Before 2021

To understand the 2021 E/M coding changes, you need to know the basics of how E/M coding worked previously.

AMA’s 2020 CPT^® code set included guidelines on using patient history, clinical examination, and medical decision making (MDM) to determine the correct level of E/M codes. The guidelines also offered information on how to use time to select E/M codes when counseling, coordination of care, or both made up more than 50 percent of the intraservice time.

Not all E/M codes used history, exam, MDM, or time for code selection, but office and outpatient visit codes 99201-99215 were among those that did in 2020. For example, note the references to history, examination, and MDM, as well as the typical time spent, in these 2020 CPT^® code descriptors for level-3 E/M codes 99203 and 99213 (bold added for emphasis):

99203 Office or other outpatient visit for the evaluation and management of a new patient, which requires these 3 key components: A detailed history; A detailed examination; Medical decision making 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 presenting problem(s) are of moderate severity. Typically, 30 minutes are spent face-to-face with the patient and/or family.

99213 Office or other outpatient visit for the evaluation and management of an established patient, which requires at least 2 of these 3 key components: An expanded problem focused history; An expanded problem focused examination; Medical decision making of low complexity. Counseling and 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 presenting problem(s) are of low to moderate severity. Typically, 15 minutes are spent face-to-face with the patient and/or family.

CMS’ 1995 and 1997 Documentation Guidelines for Evaluation and Management Services provided more details than the CPT^® guidelines on how to select a final E/M code based on the key components or time. But at 16 pages and 49 pages respectively, these Documentation Guidelines created a lot of work for coders and providers. By 2021, the Documentation Guidelines were also more than 25 years old, which is a long time in the always-evolving world of healthcare. 

MPFS 2019 Plans for Office/Outpatient E/M in 2021

There had been many calls to simplify E/M coding over the years, but the 2019 Medicare Physician Fee Schedule (MPFS) rule is particularly helpful for understanding the background of the 2021 E/M updates.

The MPFS is funded by Medicare Part B and is a listing of fee maximums Medicare uses to pay physicians and other healthcare professionals on a fee-for-service basis. Each year CMS publishes a proposed rule and a final rule explaining changes planned for the next year’s MPFS.

The 2019 MPFS final rule included substantial changes for E/M office outpatient codes 99201-99215. The stated goals were reducing administrative burden, improving payment accuracy, and updating the code set to reflect current medical practice.

One policy change in the 2019 MPFS final rule that got a large reaction from providers was a plan to pay a single rate, called a blended rate, for E/M visit levels 2 to 4 starting in 2021. In other words, Medicare intended to pay the same rate for new patient codes 99202, 99203, and 99204, regardless of which code was reported. Medicare was going to pay another single rate for established patient codes 99212, 99213, and 99214. Level-5 visits (99205, 99215) would have separate rates to reflect the increased complexity those codes represent.

Although this plan for blended rates was in the 2019 final rule, Medicare later stated this fee-structure change would not go through. The MPFS continued to list distinct payment rates for each office/outpatient E/M code in 2021. Medicare eliminated the blended rates because of E/M code revisions and new valuation data AMA produced in response to the MPFS plan. You will read more about those codes in the sections below.

The 2019 MPFS final rule also indicated Medicare would allow practitioners to document office and outpatient levels 2 to 5 using only MDM or time starting in 2021. Providers would be allowed to continue to use the 1995 and 1997 Documentation Guidelines as the basis for their coding if they preferred. However, as you will see, AMA’s 2021 E/M code revisions eliminated the need for use of the 1995 and 1997 Documentation Guidelines for office/outpatient E/M codes.

Another important change related to E/M in the 2019 final rule was a plan to add HCPCS Level II G codes (codes that start with the letter G) to reflect additional resources used for primary care and certain specialist visits. These codes were intended for use with level 2 to 4 visits. A new “extended visit” G code was planned for use with levels 2 to 4, as well, all beginning in 2021. These expectations also changed, as you’ll discover later in this article.

AMA’s 2021 Office/Outpatient E/M Codes: New Patient

As an alternative to Medicare’s plans, the AMA developed new guidelines and code descriptors for office and outpatient E/M codes. The effective date was Jan. 1, 2021. Because of the update's large impact on healthcare providers, the AMA posted the revised 2021 office and outpatient E/M guidelines and code descriptors for review before the effective date. Let’s start with the new patient codes and descriptors.

99201: The 2021 CPT^® code set did not include new-patient level-1 code 99201. As you’ll see below, the revised code descriptors for the remaining office and outpatient E/M codes used MDM or time to dictate code selection. Code 99201 required straightforward MDM, the same as 99202, and having two codes requiring the same level of MDM would be redundant.

99202-99205: In 2021, new patient codes 99202-99205 no longer required the three key components or referenced typical face-to-face time. Instead, each service included “a medically appropriate history and/or examination,” and code selection was based on the MDM level or total time spent on that date.

Compare the 2020 descriptor for 99203 posted earlier in this article to the 2021 code descriptor below:

99203 Office or other outpatient visit for the evaluation and management of a new patient, which requires a medically appropriate history and/or examination and low level of medical decision making. When using time for code selection, 30-44 minutes of total time is spent on the date of the encounter.

The descriptors for 2021 codes 99202-99205 all followed the same structure as the 99203 example above. Table 1 shows the requirements for the new patient E/M codes in 2021.

Table 1: 2021 Requirements for E/M Codes 99202-99205

For services longer than 74 minutes, the AMA created a new prolonged services add-on code, +99417 Prolonged office or other outpatient evaluation and management service(s) beyond the minimum required time of the primary procedure which has been selected using total time, requiring total time with or without direct patient contact beyond the usual service, on the date of the primary service, each 15 minutes of total time (List separately in addition to codes 99205, 99215 for office or other outpatient Evaluation and Management services).

Medicare created a HCPCS Level II code to use in place of +99417 when coding for Medicare patients. The sections below about prolonged services provide more details about these codes.

AMA’s 2021 Office/Outpatient E/M Codes: Established Patient

The office and other outpatient E/M codes for established patients changed in line with the revisions to the new patient codes in 2021.

99211: Level-1 established patient E/M code 99211 was still available, but the 2021 code descriptor did not include the time reference that was in the 2020 descriptor:

99211 Office or other outpatient visit for the evaluation and management of an established patient, that may not require the presence of a physician or other qualified health care professional. Usually, the presenting problem(s) are minimal. Typically, 5 minutes are spent performing or supervising these services.

99212-99215: Established patient E/M codes 99212-99215 look a lot like the new patient codes in 2021. For instance, review the revised descriptor for 99213:

99213 Office or other outpatient visit for the evaluation and management of an established patient, which requires a medically appropriate history and/or examination and low level of medical decision making. When using time for code selection, 20-29 minutes of total time is spent on the date of the encounter.

Table 2 shows the requirements for the 2021 established patient codes. Note that the times required for each level differed for the new patient and established patient codes. For instance, level-5 new-patient code 99205 had a time of 60-74 minutes while level-5 established-patient code 99215 listed 40-54 minutes.

Table 2: 2021 Requirements for E/M Codes 99212-99215

You could use new prolonged services code +99417 as an add-on code with 99215 for services 55 minutes or longer for payers following AMA rules. As noted above, Medicare provided a different code for prolonged services, and that code had its own rules.

2021 CPT^® E/M Guidelines Overview

Because of the 2021 changes to the office and outpatient E/M codes, the CPT^® E/M guidelines saw revisions, as well. Some of the guideline updates related directly to the new code requirements, but the guidelines also featured changes throughout to ensure no outdated references involving the office/outpatient codes remained.

For instance, the CPT^® E/M services guidelines added these headings:

• Guidelines Common to All E/M Services

• Guidelines for Hospital Observation, Hospital Inpatient, Consultations, Emergency Department, Nursing Facility, Domiciliary, Rest Home, or Custodial Care, and Home E/M Services

• Guidelines for Office or Other Outpatient E/M Services

2021 CPT^® E/M Guidelines for Time and Separate Services

When reviewing the 2021 Guidelines Common to All E/M Services, the entries for Time and Services Reported Separately required particular attention.

Time: The Time section of the 2021 E/M guidelines included important information about proper use of the revised office and other outpatient codes. Here are the major points from the 2021 guidelines for Time:

• You could use time alone to select the correct code from 99202-99205 and 99212-99215. Note that 99211 was not in that list because no time was listed in that descriptor

• Counseling and/or coordination of care did not need to dominate an office or other outpatient E/M service for you to code the service based on time in 2021. But for other E/M services that you coded based on time, you still had to meet the threshold of counseling and/or coordination of care taking up more than 50 percent of the visit.

• You used 99211 if clinical staff members performed the face-to-face visit under the supervision of the physician or other qualified healthcare professional.

• A shared or split visit was when a physician and one or more other qualified healthcare professionals performed the face-to-face and non-face-to-face work for the E/M visit. When coding these visits based on time, you summed the time spent by the physician and other qualified healthcare professionals to get a total time. You counted any time that the providers spent together to meet with or discuss the patient only once. For instance, if two providers met for 15 minutes, you added 15 minutes to the total time, not 30 minutes (15 minutes x two providers).

• A key shift for the office and other outpatient E/M codes is that the time referenced in the 2021 code descriptors was total time. The 2020 descriptors for these codes used intraservice time.

  • The 2021 Time guidelines explained that for 99202-99205 and 99212-99215, total time on the encounter date included both face-to-face and non-face-to-face time spent by the provider.

  • The guidelines offered the examples of preparing for the visit (such as reviewing tests); getting or reviewing a history that was separately obtained; performing the exam; counseling and providing education to the patient, family, or caregiver; ordering medicines, tests, or procedures; communicating with other healthcare professionals; documenting information in the medical record; interpreting results and sharing that information with the patient, family, or caregiver; and care coordination.

  • When you counted time for the 2021 codes, you did not include time spent on services you reported separately. For instance, if you reported care coordination using a separate code, you did not include that service’s time in the time for the E/M code.

  • The total time also did not include time for activities the clinical staff normally performs.

Services Reported Separately: The 2020 CPT^® E/M guidelines included information about services reported separately, but the 2021 guidelines gave this information its own heading and added some clarifications. In particular, note this line: “If a test/study is independently interpreted in order to manage the patient as part of the E/M service, but is not separately reported, it is part of medical decision making.”

2021 CPT^® E/M Guidelines for Office/Outpatient History and Exam

The Guidelines for Office or Other Outpatient E/M Services helped with understanding the revised E/M codes and how to apply them in 2021.

The History and/or Examination portion of these E/M guidelines explained that office and other outpatient E/M services included “a medically appropriate history and/or physical examination, when performed.”

“Medically appropriate” meant that the physician or other qualified healthcare professional reporting the E/M determined the nature and extent of any history or exam for a particular service. Remember that code selection did not depend on the level of history or exam. That’s why the guidelines don’t quantify these elements.

The history and exam guidelines for office and outpatient E/M visits also specified that the “care team” could collect information, and the patient (or caregiver) could provide information, such as by portal or questionnaire. The reporting provider then had to review that information.

2021 CPT^® E/M Guidelines for MDM

Because you used either total encounter time or MDM to select the level of office or other outpatient E/M in 2021, CPT^® clarified and expanded the MDM guidelines, including the addition of a new Level of Medical Decision Making (MDM) table.

The MDM guidelines and table were in the CPT^® E/M guidelines section for Instructions for Selecting a Level of Office or Other Outpatient E/M Service, but you used them together with information and definitions in the section called Number and Complexity of Problems Addressed at the Encounter.

In the 2021 MDM guidelines, CPT^® stated that MDM “includes establishing diagnoses, assessing the status of a condition, and/or selecting a management option.” Three elements defined MDM for office/outpatient visits in 2021, and they were similar but not identical to the 2020 elements:

1. The number and complexity of the problem or problems the provider addressed during the E/M encounter.

• In 2020, the guidelines instead referred to “the number of possible diagnoses and/or the number of management options.”

2. “The amount and/or complexity of data to be reviewed and analyzed.” The 2021 guidelines listed three categories for data: (1) tests, documents, orders, or independent historians, (2) independent test interpretation, and (3) discussion of management or test interpretation with external providers or appropriate sources. The latter term referred to nonhealthcare, nonfamily sources involved in patient management, like a parole officer or case manager.

• The 2020 MDM guidelines also included the amount and/or complexity of medical records, test, and other information involved, but the 2021 guidelines expanded the section significantly.

3. “The risk of complications and/or morbidity or mortality of patient management decisions made at the visit.” The 2021 guidelines made it clear that options considered, but not selected, were still a factor for this element, specifically after “shared” MDM with the patient, family, or both. Examples included deciding against hospitalization for a psychiatric patient with sufficient support for outpatient care or choosing palliative care for a patient with advanced dementia and an acute condition.

• The 2020 MDM guidelines included comparable wording, but they did not include the reference to shared MDM or the examples found in the 2021 guidelines.

2021 Levels of Medical Decision Making (MDM) Table

The AMA CPT^® Editorial Panel used the Table of Risk that’s in the CMS 1995 and 1997 Documentation Guidelines, as well as current CMS contractor audit tools, as a basis for the 2021 MDM updates.

The 2021 MDM table in the CPT^® E/M guidelines had three main columns with the final column divided into three additional columns:

• Code

• Level of MDM (Based on 2 out of 3 Elements of MDM)

• Elements of Medical Decision Making

  • Number and Complexity of Problems Addressed at the Encounter

  • Amount and/or Complexity of Data to be Reviewed and Analyzed

  • Risk of Complications and/or Morbidity or Mortality of Patient Management

In Tables 1 and 2 above, you saw that the MDM required for each distinct code level was the same, regardless of whether the code was for a new or established patient. For instance, level-2 codes 99202 and 99212 both required straightforward MDM.

Each row of the CPT^® MDM table showed the requirements for a specific code level, with 99211 on the first row, 99202 and 99212 on the second row, and so on. The second column showed the MDM level for the codes in column 1. The final three columns represented the three elements of MDM.

Table 3 showed the row from the CPT^® MDM table for codes 99203 and 99213 along with column headings to give an idea of the structure. The note in the Level of MDM column explained that the final choice for the MDM level should be based on meeting requirements for two out of the three elements. (In 2020, the service had to meet two out of three elements in the much smaller table CPT^® provided for that code set.)

To use the 2021 MDM table properly, you also needed to be familiar with the use of categories in the column for Amount and/or Complexity of Data to be Reviewed and Analyzed.

As Table 3 shows, for 99203 and 99213 the service had to meet the requirements for at least one of two categories. For codes 99204 and 99214, the service had to meet the requirements for one of three categories. For the highest-level codes, 99205 and 99215, the service had to meet the requirements for two of three categories. The lower-level codes didn’t have categories in that column.

Table 3: Sample Row from 2021 E/M Table for MDM Level

Elements of Medical Decision Making

Number and Complexity of Problems Addressed at the Encounter

The 2021 CPT^® guidelines included a heading for Number and Complexity of Problems Addressed at the Encounter (which matched a column name in the MDM table). This part of the guidelines included a brief discussion about how the problems addressed could affect code level selection. Under this header, there also were many definitions important to MDM.

One key point the 2021 guidelines made was that the final diagnosis wasn’t the only factor when you determined the complexity or risk. A patient could have had several lower-severity problems that combined to cause higher risk, or the provider could have needed to perform an extensive evaluation to determine a problem was of lower severity.

The 2021 guidelines also took a 2020 rule and expanded it, clarifying that comorbidities and underlying diseases did not factor into the E/M level “unless they are addressed and their presence increases the amount and/or complexity of data to be reviewed and analyzed or the risk of complications and/or morbidity or mortality of patient management.”

2021 MDM Terms and Definitions

To use the 2021 level of MDM table properly, you needed to know CPT^®’s definitions for many terms. In fact, you needed to know roughly two pages of definitions. Below is an overview of many of those terms, but you should review the official 2021 guidelines to see the complete list of definitions.

To qualify as a problem addressed (or managed) for office or other outpatient MDM, the provider had to evaluate or treat the problem at the encounter. If the provider considered further testing or treatment, but the provider or patient/caregiver decided against it, that still counted as addressed. But a simple note that another professional was managing a problem did not count as addressed. There had to be additional assessment or care coordination to meet the requirements of addressing a problem. Another area that did not qualify as addressing the problem was referral without evaluation (by history, exam, or diagnostic studies) or consideration of treatment.

A self-limited or minor problem was defined almost identically by the 2020 and 2021 E/M guidelines, but the 2021 guidelines deleted the text in brackets: “A problem that runs a definite and prescribed course, is transient in nature, and is not likely to permanently alter health status [OR has a good prognosis with management/compliance].” The MDM table included the term self-limited or minor problem in the column for Number and Complexity of Problems Addressed at the Encounter. Level-2 codes met the threshold for “minimal” if there was one self-limited or minor problem addressed. Level-3 codes met the threshold for “low” if two or more self-limited or minor problems were addressed.

Risk was related to the probability of something happening, but risk and probability were not the same for E/M office and outpatient coding purposes. For instance, high probability of a minor adverse effect may be low risk, depending on the case. The AMA intended the terms high, medium, low, and minimal risk to reflect the common meanings used by providers in their specialties. For MDM, the level of risk was based on the consequences of the addressed problems when appropriately treated. Risk also came into play for MDM when deciding whether to begin further testing, treatment, or hospitalization.

An external physician or other qualified healthcare professional was not in the same group practice or was classified as a different specialty or subspecialty. Review of external notes was included in the office/outpatient E/M codes for levels 3 to 5. Discussion with an external provider was included in levels 4 and 5.

An independent historian was a family member, witness, or other individual who provided patient history when the patient couldn’t provide a complete history or the provider thought a confirmatory history was needed. Assessment requiring an independent historian was included in office/outpatient E/M levels 3 to 5.

Social determinants of health (SDOH) are economic and social conditions that effect health. SDOH is something you may be familiar with from ICD-10-CM coding, specifically categories Z55.- to Z65.-, Persons with potential health hazards related to socioeconomic and psychosocial circumstances. The 2021 MDM table referenced SDOH in an example of moderate risk from additional diagnostic testing or treatment because SDOH, like housing insecurity, may limit those options.

Drug therapy requiring intensive monitoring for toxicity was in the 2021 CPT^® MDM table as an example of high risk of morbidity from additional diagnostic testing or treatment. These conditions were listed in the guidelines:

• The drug could cause serious morbidity or death.

• Monitoring assessed adverse effects, not therapeutic efficacy.

• The type of monitoring used was the generally accepted kind for that agent, although patient-specific monitoring may have been appropriate, too.

• Long-term or short-term monitoring was OK.

• Long-term monitoring occurred at least quarterly.

• Lab, imaging, and physiologic tests were possible monitoring methods. History and exam were not.

• Monitoring affected MDM level when the provider considered the monitoring as part of patient management.

• An example of drug therapy requiring intensive monitoring for toxicity was testing for cytopenia (reduction in the number of mature blood cells) between antineoplastic agent dose cycles.

Morbidity was a “state of illness or functional impairment that is expected to be of substantial duration during which function is limited, quality of life is impaired, or there is organ damage that may not be transient despite treatment.” Morbidity is an important term to understand for the acute and chronic illness definitions below.

Acute and chronic illnesses were referenced in a variety of ways in the Number and Complexity of Problems Addressed at the Encounter column of the CPT^® 2021 MDM table. Table 4 will help you compare these terms for acute and chronic illnesses.

Table 4: 2021 CPT® E/M Guideline Definitions for Acute and Chronic Illnesses

Medicare Accepted Most CPT^® E/M Coding and Guideline Changes

The MPFS 2020 final rule addressed the substantial changes that the AMA announced for E/M office/outpatient codes in 2021, stating that Medicare would adopt the MDM guidelines revised by CPT^® and would allow the use of time or MDM for office/outpatient E/M code selection. The final rule also stated that Medicare would monitor claims to watch for shifts in visit levels billed, including whether certain specialties were affected more than others.

The MPFS 2021 final rule confirmed that Medicare would generally adopt the AMA code and guideline changes, as planned. But medical coders and providers had to stay alert for Medicare rules and payer-specific variations, such as how to code for prolonged services, described below.

2021 E/M Coding for Prolonged Services: CPT^®

Because the role of time changed for office and other outpatient E/M codes in 2021, the AMA revised the Prolonged Services section of the CPT^® code set.

Codes +99354 and +99355 for prolonged E/M services requiring direct patient contact changed from applying to the office or other outpatient setting to applying to the outpatient setting. The descriptors stated that you should not use +99354 and +99355 as add-on codes with office/outpatient codes 99202-99205 and 99212-99215. The guidelines for these prolonged services codes (and other prolonged services codes) also saw revisions to factor in new 2021 CPT^® code +99417.

The code descriptor is a good place to start to get to know the new office/outpatient prolonged services code:

+99417 Prolonged office or other outpatient evaluation and management service(s) beyond the minimum required time of the primary procedure which has been selected using total time, requiring total time with or without direct patient contact beyond the usual service, on the date of the primary service, each 15 minutes of total time (List separately in addition to codes 99205, 99215 for office or other outpatient Evaluation and Management services)

Pay special attention to these points in the descriptor:

• Code +99417 applied only when you chose the primary E/M code based on time (not MDM).

• The new code included total time with and without direct patient contact on the date of service. Remember that 99202-99205 and 99212-99215 also used total time rather than intraservice time in 2021.

• You used +99417 once for each 15 minutes beyond the minimum required primary service time.

• There were only two appropriate primary codes: 99205, which represented the longest time among the new patient codes, and 99215, which represented the longest time among the established patient codes.

New CPT^® guidelines that accompanied +99417 stated you should not report the code for any time period under 15 minutes. Under CPT^® rules you start counting based on the minimum time required for the code. For instance, 99205 represented 60-74 minutes in 2021. You could add +99417 as soon as the encounter reached 75 minutes, which is 15 minutes beyond the minimum required time of 60 minutes. You should not have assigned another unit of +99417 until the encounter reached 90 minutes, which was 15 minutes more than 75 minutes. In other words, you assigned 99205 and +99417 to report 75-89 minutes. For 90-104 minutes, you reported 99205 and two units of +99417.

A parenthetical instruction with the code stated that you should not report +99417 on the same date as other prolonged services codes +99354, +99355, 99358, +99359, +99415, and +99416.

Keep in mind that Medicare created a code to use in place of +99417, as will be explained below.

Medicare-Specific HCPCS Code for Prolonged Services

Medicare created a new HCPCS Level II code for use in place of CPT^® code +99417 when billing Medicare for prolonged office/outpatient E/M services. This is the 2021 descriptor:

+G2212 Prolonged office or other outpatient evaluation and management service(s) beyond the maximum required time of the primary procedure which has been selected using total time on the date of the primary service; each additional 15 minutes by the physician or qualified healthcare professional, with or without direct patient contact (list separately in addition to CPT^® codes 99205, 99215 for office or other outpatient evaluation and management services) (do not report g2212 on the same date of service as 99354, 99355, 99358, 99359, 99415, 99416). (do not report g2212 for any time unit less than 15 minutes)

The main difference between the two codes was that +99417 applied to prolonged services 15 minutes beyond the minimum required time and +G2212 applied to prolonged services 15 minutes beyond the maximum required time.

The MPFS 2021 final rule explained Medicare’s position that allowing +99417 for 15 minutes beyond the minimum time, instead of the maximum, resulted in “double counting” time. The MPFS provided this example: 99215 had a time range of 40-54 minutes. If the provider reported prolonged services at 55 minutes, then 14 of those “prolonged” minutes were also captured in 99215. The AMA argued against Medicare’s reasoning when commenting on MPFS 2021, but Medicare finalized +G2212 and required that code for Medicare claims. Healthcare organizations needed to confirm with other payers which prolonged services code they accepted and which rules they applied.

Medicare-Specific HCPCS Code for Visit Complexity

The 2019 MPFS final rule included a plan to create two new G codes to represent the visit complexity inherent to certain services, with one code for designated specialists and a second code for primary care providers. The 2020 MPFS final rule changed that, adopting a single new G code instead for use in 2021. The 2021 MPFS final rule changed the descriptor slightly and confirmed the code would be part of the 2021 HCPCS Level II code set:

+G2211 Visit complexity inherent to evaluation and management associated with medical care services that serve as the continuing focal point for all needed health care services and/or with medical care services that are part of ongoing care related to a patient's single, serious condition or a complex condition. (add-on code, list separately in addition to office/outpatient evaluation and management visit, new or established)

The MPFS 2021 final rule indicated Medicare would reimburse providers for this code, but December 2020 legislation related to COVID-19 relief changed this by including a moratorium on payment for +G2211 until at least January 2024. This delay also allowed additional time for Medicare to clarify proper use of this code.

RVUs for 2021 Office/Outpatient E/M Codes

E/M visits comprised approximately 40 percent of allowed charges for MPFS services, and office/outpatient E/M visits comprised approximately 20 percent of allowed charges, the MPFS 2021 final rule stated. As a result, pricing of these codes was an important subject, both for providers and for Medicare.

Fees on the MPFS are calculated using work relative value units (RVUs), malpractice RVUs, and practice expense RVUs multiplied by a conversion factor and adjusted based on geographic location. Additional factors such as other services reported for the patient, modifiers, and the patient’s financial responsibility also can affect how much a provider receives from Medicare.

Table 5 shows the first-quarter 2021 and fourth-quarter 2020 total RVUs for 99202-99215 (the MPFS is updated quarterly). The table also includes the 2021 RVUs for new prolonged services code +G2212. MPFS facility RVUs are often lower than nonfacility (office) RVUs because when a physician provides services in a facility, the physician is responsible for fewer practice expenses. Remember that the final reimbursement amounts for E/M services depend on more than just these RVUs.

Table 5: Total RVUs for Office/Outpatient E/M Codes

Last reviewed on March 3, 2026, by the AAPC Thought Leadership Team