EM Coding Alert

Here are all the guidelines you need to know to bill 99421-99423.

The deletion of 99444 at the beginning of the year left many E/M coders in the dark about the best way to bill for online digital encounters.

If you were one of them, take heart. Because we put together four great tips that you can rely on to understand — and get paid for — the new online digital E/M codes.

Tip 1: Discover the New Guidelines for 99421-99423

CPT^® 2020 will delete current online E/M code 99444. In the place of 99444, you will gain new online digital E/M codes 99421 (Online digital evaluation and management service, for an established patient, for up to 7 days, cumulative time during the 7 days; 5-10 minutes), 99422 (… 11-20 minutes), and 99423 (… 21 or more minutes).

CPT^® guidelines define 99241-99423 as “patient-initiated services with physicians or other qualified health care professionals (QHPs).” Follow these rules when reporting 99421-99423:

• Rule 1: Online digital E/M services require a physician or other QHP’s evaluation, assessment, and management of the patient. You should not report 99421-99423 for “the nonevaluative electronic communication of test results, scheduling of appointments, or other communication that does not include E/M,” per CPT^®.
• Rule 2: Patients should use Health Insurance Portability and Accountability Act (HIPAA)-compliant platforms to initiate online the digital E/M services. Examples of such platforms include electronic health record (EHR) portals, secure email, and other digital applications.
• Rule 3: The patient must be established to appropriately report 99421-99423, but the patient’s problem can be new to the physician or other QHP.
• Rule 4: The physician or other QHP must permanently store the documentation from all online digital E/M encounters. This can be an electronic or hard copy.
• Rule 5: You should not calculate clinical staff time as part of cumulative time for 99421-99423.
• Rule 6: Never report online digital E/M services for cumulative service time that is less than five minutes.

Tip 2: Never Report 99421-99423 in Conjunction With These Codes

When you report 99421-99423, you must understand which codes you cannot report in conjunction with these online digital codes. For example, you should never report 99421-99423 on a day when the physician or other QHP reports new patient office or other outpatient service codes 99201-99205, established patient office or other outpatient codes 99212-99215, and new or established patient office or other outpatient consultation codes 99241-99245.

Additionally, you should never report 99421-99423 when you use digitally stored data and remote physiologic monitoring code 99091, domiciliary, rest home, or home care plan oversight codes 99339 and 99340, care plan oversight codes 99374-99380, or transitional care codes 99495 and 99496 for the same communications.

Lastly, you should never report 99421-99423 for home and outpatient international normalized ratio (INR) monitoring when reporting home and outpatient INR monitoring codes 93792 and 93793.

Tip 3: Discover Cumulative Service Time Components

When they perform 99421-99423 services, the physician’s or other QHP’s cumulative service time includes multiple components, according to CPT^®. They are as follows:

• Reviewing the patient’s initial inquiry, which is when the seven-day period begins.
• Reviewing the patient’s records or reviewing data relevant to assessing the patient’s problem.
• Personal physician or other QHP interaction with the clinical staff that focuses on the patient’s problem.
• Developing management plans, which includes when the physician or other QHP generates prescriptions or orders tests.
• Any subsequent communication with the patient through online, telephone, email, or other digitally supported communications, which “does not otherwise represent a separately reported E/M service.”

Important: “All professional decision making, assessment, and subsequent management by physicians or other QHPs in the same group practice contribute to the cumulative service time of the patient’s online digital E/M service,” per CPT^®.

Tip 4: Observe 7-Day Period Criteria

You should report online digital E/M services once for the physician’s or other QHP’s cumulative time they devote to the online digital service over a seven-day period, according to CPT^®. Heed the following to make sure you understand how to correctly report codes during this seven-day period:

• If a separately reported E/M visit occurs within seven days of the online digital service’s initiation, then the work the physician or QHP devotes to the online digital E/M service should be incorporated into the separately reported E/M visit, per CPT^®. This includes any E/M visit and procedures the physician or QHP provides through synchronous telemedicine using interactive audio and video telecommunication equipment, which you should report by appending modifier 95 (Synchronous telemedicine service rendered via a real-time interactive audio and video telecommunications system) to the E/M code.
• If a patient initiates an online digital inquiry for the same or a related problem within seven days of a previous E/M service, you shouldn’t report the online digital visit. Also, if the online digital inquiry is “related to a surgical procedure and occurs during the postoperative period of a previously completed procedure,” you should not separately report the online digital E/M service, according to CPT^®.
• If the patient generates “the initial online digital inquiry for a new problem within seven days of a previous E/M visit that addressed a different problem,” you can separately report the online digital E/M service.
• If the patient presents a new, unrelated problem during the online digital service’s seven-day period, then you should add the time the physician or other QHP spent on evaluating, assessing, and managing the additional problem to the cumulative service time of the online digital E/M service.