EM Coding Alert

Say goodbye to per-day observation codes.

2023 is just around the corner, and so are updates to evaluation and management (E/M) codes.

The American Medical Association (AMA) has announced the coming changes, and there are some big revisions to consider!

The skinny: As with office/outpatient E/M codes in 2021, the AMA is changing descriptors for (or outright deleting) several code ranges in the other E/M subsections of CPT^®. In some cases, these changes mirror what the AMA did in 2021; but there are some differences.

“Overall, the CPT^® Editorial Panel worked to, again, create revisions to the E/M code descriptors and guidelines that met their objective to decrease the administrative burden of excessive documentation whenever possible,” says Mary I. Falbo, MBA, CPC, CEO of Millennium Healthcare Consulting Inc. in Lansdale, Pennsylvania. Read on to see what E/M coding changes you’ll have to observe when CPT^® 2023 takes effect Jan. 1, 2023.

Goodbye Original Per-Day Observation Codes

In one stroke, CPT^® is getting rid of its per-day observation codes.

What’s being deleted? CPT^® 2023 will delete the following codes:

• 99218 (Initial observation care, per day, for the evaluation and management of a patient which requires these 3 key components: A detailed or comprehensive history; A detailed or comprehensive examination; and Medical decision making that is straightforward or of low complexity…)
• 99219 (… A comprehensive history; A comprehensive examination; and Medical decision making of moderate complexity...)
• 99220 (… A comprehensive history; A comprehensive examination; and Medical decision making of high complexity...)

What should I do? CPT^® 2023 will include the following coding directive:

• “99218, 99219, 99220 have been deleted. To report initial observation care, new or established patient, see 99221, 99222, 99223.”

In addition to the above deletions, CPT^® also rids itself of 99217 (Observation care discharge day management…) in 2023. According to CPT^®, “99217 has been deleted. To report observation care discharge services, see 99238, 99239.”

Look for Discharge Services Under 99238, 99239

Reporting discharge services will be different next year, as CPT^® created descriptors that will allow for one set of codes to be used for hospital inpatient or observation discharge day management.

What’s being changed? CPT^® 2023 will revise the descriptors for the following codes:

• 99238 (Hospital discharge day management; 30 minutes or less)
• 99239 (… more than 30 minutes)

What’s being added? CPT^® 2023 will change to these descriptors for the above-listed codes:

• 99238 (Hospital inpatient or observation discharge day management; 30 minutes or less on the date of the encounter)
• 99239 (… more than 30 minutes on the date of the encounter)

Impact: CPT^® is putting hospital inpatient or observation discharge day management services into the same code descriptors. You’ll use 99238 and 99239 for both these types of discharges.

Watch for CPT^® Overhaul of Observation Section

CPT^® 2023 will retain its original initial per-day hospital care codes, but they will be vastly different and more inclusive of observation services.

What’s being changed? CPT^® 2023 will revise the descriptors for the following codes:

• 99221 (Initial hospital care, per day, for the evaluation and management of a patient, which requires these 3 key components: A detailed or comprehensive history; A detailed or comprehensive examination; and Medical decision making that is straightforward or of low complexity…)
• 99222 (… A comprehensive history; A comprehensive examination; and Medical decision making of moderate complexity…)
• 99223 (… A comprehensive history; A comprehensive examination; and Medical decision making of high complexity...)

What’s being added? CPT^® 2023 will change to these descriptors for the above-listed codes:

• 99221 (Initial hospital inpatient or observation care, per day, for the evaluation and management of a patient, which requires a medically appropriate history and/or examination and straightforward or low level medical decision making. When using total time on the date of the encounter for code selection, 40 minutes must be met or exceeded.)
• 99222 (Initial hospital inpatient or observation care, per day, … moderate level of medical decision making … 55 minutes must be met or exceeded.)
• 99223 (Initial hospital inpatient or observation care, per day … high level of medical decision making … 75 minutes must be met or exceeded.)

Impact: As the descriptors indicate, you will use 99221 through 99223 for all your multi-day hospital inpatient or observation services. For these services, you will choose from the revised 99238 or 99239 codes for discharge.

As with most of the 2023 E/M changes, Falbo says these changes should make things easier for coders and providers, “since there will be consistency in both outpatient and inpatient, where MDM [medical decision making] and time are the key factors.” There will also be “less administrative burden on meeting specific requirements for history and exam,” she says.