# **New: AMA Provides Clarifications to 2021 Guidelines**



## kimberlywatson (Mar 11, 2021)

The AMA has published official clarifications to some of the new 2021 E/M Guidelines. See below:

https://www.ama-assn.org/system/files/2019-06/cpt-office-prolonged-svs-code-changes.pdf


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## Anna_Odor (Mar 11, 2021)

Thank you Kimberly! Have you found any additional help to this PDF maybe? There are several definitions that are unclear.


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## kimberlywatson (Mar 12, 2021)

Anna_Odor said:


> Thank you Kimberly! Have you found any additional help to this PDF maybe? There are several definitions that are unclear.


I agree! Unfortunately I haven't seen anything else since this. If I do I'll definitely share!


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## rachelb117 (Mar 12, 2021)

In reviewing the updates to the new guidelines, I am curious how everybody interprets a part of the data update.  Are labs considered part of MDM now as they are results only and not interpreted with a report?  We have an onsite lab and were under the assumption that we could not count labs as we bill for them.  Now the guidelines have added terminology that sounds like labs ordered could be counted in the data section of MDM.


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## kimberlywatson (Mar 12, 2021)

Yes that’s correct. You can count as part of the MDM because the labs don’t have a professional component.


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## smihm (Mar 15, 2021)

This is huge!!!  I have not been able to locate any further information on this , so for example we order and perform rapid covid testing in office we can count that now ?  I do work for a practice that has an inhouse lab , this sounds like we can now count all lab orders- Pediatrics we do a significant number of inhouse testing covid, strep, flu, cbc etc


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## lflatt (Mar 25, 2021)

I'm just seeing this.  To repeat, if we do a pregnancy test in our office and bill for it, we can still count it in data because there is no professional component (26 modifier) included in the CPT code.  Same for office hematocrits, urinalysis, etc.


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## csperoni (Mar 25, 2021)

The current answer is yes, you get a data point since there is no professional component.  I'm copying & pasting my post from a very similar thread:
https://www.ama-assn.org/system/files/2019-06/cpt-office-prolonged-svs-code-changes.pdf  Below the changes are *bold in blue*
Services Reported Separately
Any specifically identifiable procedure or service (ie, identified with a specific CPT code) performed on the date of E/M services may be reported separately. The *ordering and* actual performance and/or interpretation of diagnostic tests/studies during a patient encounter are not included in determining the levels of E/M services when* the professional interpretation of those tests/studies is* reported separately *by the physician or other qualified health care professional reporting the E/M service. Tests that do not require separate interpretation (eg, tests that are results only) and are analyzed as part of MDM do not count as an independent interpretation, but may be counted as ordered or reviewed for selecting an MDM level.* Physician performance of diagnostic tests/studies for which specific CPT codes are available may be reported separately, in addition to the appropriate E/M code. The physician’s interpretation of the results of diagnostic tests/studies (ie, professional component) with preparation of a separate distinctly identifiable signed written report may also be reported separately, using the appropriate CPT code and, if required, with modifier 26 appended. 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 MDM. The physician or other qualified health care professional may need to indicate that on the day a procedure or service identified by a CPT code was performed, the patient’s condition required a significant separately identifiable E/M service. The E/M service may be caused or prompted by the symptoms or condition for which the procedure and/or service was provided. This circumstance may be reported by adding modifier 25 to the appropriate level of E/M service. As such, different diagnoses are not required for reporting of the procedure and the E/M services on the same date.

The interpretation of these changes has been that if a test does not have a professional component (such as many in house lab tests like UA, strep, etc.), the change means you may count the ordering or review for data of MDM. "Tests that do not require separate interpretation ..... may be counted as ordered or reviewed for selecting an MDM level."


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## SR2020 (Mar 26, 2021)

csperoni said:


> The current answer is yes, you get a data point since there is no professional component.  I'm copying & pasting my post from a very similar thread:
> https://www.ama-assn.org/system/files/2019-06/cpt-office-prolonged-svs-code-changes.pdf  Below the changes are *bold in blue*
> Services Reported Separately
> Any specifically identifiable procedure or service (ie, identified with a specific CPT code) performed on the date of E/M services may be reported separately. The *ordering and* actual performance and/or interpretation of diagnostic tests/studies during a patient encounter are not included in determining the levels of E/M services when* the professional interpretation of those tests/studies is* reported separately *by the physician or other qualified health care professional reporting the E/M service. Tests that do not require separate interpretation (eg, tests that are results only) and are analyzed as part of MDM do not count as an independent interpretation, but may be counted as ordered or reviewed for selecting an MDM level.* Physician performance of diagnostic tests/studies for which specific CPT codes are available may be reported separately, in addition to the appropriate E/M code. The physician’s interpretation of the results of diagnostic tests/studies (ie, professional component) with preparation of a separate distinctly identifiable signed written report may also be reported separately, using the appropriate CPT code and, if required, with modifier 26 appended. 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 MDM. The physician or other qualified health care professional may need to indicate that on the day a procedure or service identified by a CPT code was performed, the patient’s condition required a significant separately identifiable E/M service. The E/M service may be caused or prompted by the symptoms or condition for which the procedure and/or service was provided. This circumstance may be reported by adding modifier 25 to the appropriate level of E/M service. As such, different diagnoses are not required for reporting of the procedure and the E/M services on the same date.
> ...


Based on this -say a patient comes in for missed period and no contraceptive. Patient is 29 years. Urine test is negative or positive. can this urine test be billed as 81025 with the E/M or just bill the E/M?


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## kellykckc@yahoo.com (Apr 29, 2021)

So if my rheumo md orders 6 different labs & we bill for the labs (cbc, cmp, rra essay, etc) then they still get credit for the order in the data section, based on 3/9 revision, correct?


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## csperoni (Apr 29, 2021)

kellykckc@yahoo.com said:


> So if my rheumo md orders 6 different labs & we bill for the labs (cbc, cmp, rra essay, etc) then they still get credit for the order in the data section, based on 3/9 revision, correct?


Yes, when I read "Tests that do not require separate interpretation (eg, tests that are results only) and are analyzed as part of MDM do not count as an independent interpretation, but may be counted as ordered or reviewed for selecting an MDM level.", that means you can count tests like CBC, CMP, etc as they are results only.  You cannot count x-rays, sonograms, or anything that requires interpretation.


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