Medicare Compliance & Reimbursement

Understand how Medicare policy factors into the equation.

On Sept. 8, the American Medical Association (AMA) released the 2024 CPT^® code set, and it’s chock full of changes, including 230 new codes, 70 revisions, and 49 deletions.

Medicare providers will want to pay close attention to the revised codes, as the new CPT^® code book will feature revisions to all of the office/outpatient evaluation and management (E/M) codes.

“They made the change to be consistent with the language of the other timed E/M codes,” says Melanie Witt, RN, MA, CPC, an independent coding expert based in Guadalupita, New Mexico.

Read on for the scoop.

Clock in for More E/M Changes

Over the last few years, the AMA has made extensive changes to the CPT^® E/M codes and guidelines, and 2024 will see additional changes. However, you’ll be relieved to know that next year’s E/M changes are minimal. But that doesn’t mean they’re insignificant.

Effective Jan. 1, 2024, new and established office/outpatient E/M codes will no longer have time ranges and will instead feature a single total time amount for each code. The total time amount is the minimum number of minutes in the current E/M code descriptor ranges, and the time must be “met or exceeded” according to the new code descriptors.

Examine the descriptor differences between 2023 and 2024 below:

• 2023: “total time … spent on the date of the encounter”
• 2024: “total time on the date of the encounter” that “must be met or exceeded”

For example: The descriptor for the time element has been revised, as you’ll see in the current and new 99202 descriptors below. (What’s being deleted is underlined and struck through; what’s being added is underlined and in bold.)

Current descriptor: 99202 (Office or other outpatient visit for the evaluation and management of a new patient, which requires a medically appropriate history and/or examination and straightforward medical decision making. When using time for code selection, 15-29 minutes of total time is spent on the date of the encounter.)

Revised descriptor: 99202 (Office or other outpatient visit for the evaluation and management of a new patient, which requires a medically appropriate history and/or examination and straightforward medical decision making.When using total time on the date of the encounter for code selection, 15 minutes must be met or exceeded.)

The other office/outpatient E/M codes will change similarly; here’s a look at what’s changing in each of these codes in 2024:

• 99203 (… When using total time on the date of the encounter for code selection, 30 minutes must be met or exceeded.)
• 99204 (…When using total time on the date of the encounter for code selection, 45 minutes must be met or exceeded.)
• 99205 (… When using total time on the date of the encounter for code selection, 60 minutes must be met or exceeded.)
• 99212 (… When using total time on the date of the encounter for code selection, 10 minutes must be met or exceeded.)
• 99213 (… When using total time on the date of the encounter for code selection, 20 minutes must be met or exceeded.)
• 99214 (… When using total time on the date of the encounter for code selection, 30 minutes must be met or exceeded.)
• 99215 (… When using total time on the date of the encounter for code selection, 40 minutes must be met or exceeded.)

In table form, the changes look like this:

Consider This Expert Analysis

The new language clarifies that you can use all of the time spent on that patient when leveling your E/M — but only on the date of the encounter.

The AMA’s decision to change the office/outpatient E/M time requirements from a range to a minimum number of minutes reflects Medicare policy. “This revision safeguards providers from using CPT^® language that is inconsistent with Medicare policy. Medicare does not permit time ranges to be documented for certain services, and wants a specific amount (e.g., integer) of time identified in the documentation,” says Carol Pohlig, BSN, RN, CPC, manager of coding and education in the department of medicine at the Hospital of the University of Pennsylvania in Philadelphia.

Check Out This Handy Medicare Tool

If you’re struggling to find the latest federal resources on evaluation and management (E/M) services, look no further than the recently beefed-up Medicare Provider Compliance Tips webpage.

Details: The Centers for Medicare & Medicaid Services (CMS) has significantly revised many of its educational offerings, including the handy Provider Compliance Tips, according to the Oct. 10 MLN Connects alert. One of the new topics added to the chart includes all the latest on E/M services with links to proposals and rules in the Federal Register, documentation advice, regulatory changes and requirements, coding and billing insight, and more. Take a look at the guidance at www.cms.gov/Outreach-and-Education/Medicare-Learning-Network-MLN/MLNProducts/medicare-provider-compliance-tips/medicare-provider-compliance-tips.html#EM.

Additionally, the updated E/M descriptors make them “more consistent with the rest of the code sets,” says Mary I. Falbo, MBA, CPC, CEO of Millennium Healthcare Consulting Inc. in Lansdale, Pennsylvania. This is evidenced by codes like 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.) or 99234 (Hospital inpatient or observation care, for the evaluation and management of a patient including admission and discharge on the same date, which requires a medically appropriate history and/or examination and straightforward or low level of medical decision making. When using total time on the date of the encounter for code selection, 45 minutes must be met or exceeded.), which have time minimums, but not time ranges.

“Per the AMA, the codes’ time ranges will be replaced with threshold times, which will bring them in line with the rest of the level-based code set,” explains Falbo. “This is what they have done for the inpatient code sets.”

Note: CPT^® will not be changing the descriptor to 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), which you will continue to bill for established patients receiving E/M services from a nurse practitioner (NP), a physician assistant (PA), or any other nonphysician practitioner (NPP). The code will also continue to require no level of medical decision making (MDM) or total time for you to document.