Orthopedic Coding Alert

Count the minutes to decide on E/M level.

In the sphere of in-office evaluation and management (E/M) service coding, there’s going to be a lot of changes to get used to when 2021 rolls around.

Why? For office visit codes, CPT^® will start using different criteria for E/M level selection in 2021. Specifically, “the basis for code selection [will be] either the level of medical decision making [MDM] performed or the total time spent performing the service on the day of the encounter,” explains Rae Jimenez, CPC, CIC, CPB, CPMA, CPPM, CPC-I, CCS, senior vice president of product at AAPC and coding liaison to the AMA CPT^® Editorial Panel.

We’ll be taking a look at these E/M changes in detail throughout the year to get you prepared for 2021. In this issue, you’ll see how CPT^® is defining time in 2021 and get a look at a clinical example that illustrates the 2021 time component changes.

A Brief History of (E/M) Time

In 2020 and in years previous, time has been listed in CPT^® manuals as a guide for E/M codes. In certain situations, providers used time as their guide when deciding E/M level — such as when counseling and/or coordination of care dominated total encounter time.

“But time was not intended to be the factor in deciding the E/M level,” explain Alicia Scott CPC, CPC-I, CRC, director of education for CCO.us; and Jennifer Sanders, CPC, CPB, CPMA, CPPM, COSC, CPC-I, instructor and subject matter expert at CCO.us.

That’s about to change.

In 2021, “time alone may be used to select the appropriate code level for the office or other outpatient E/M service codes,” Scott and Sanders say. “Time may be used for leveling whether or not counseling and/or coordination of care dominate the service. However, when counseling and/or coordination of care dominates the service, time may only be used for selecting the level.”

If you don’t use time as your determinant for E/M codes in 2021, your other option is to code the service to the level of medical decision making (MDM). This means that CPT^® is “removing history and examination as key components for selecting the level of E/M service, but adding the requirement that a medically appropriate history and/or examination must be performed in order to report codes 99202-99215,” explains Jimenez.

So you’ll have to know what counts as E/M encounter time, and what activities coders can count as time when adding to total encounter minutes, Scott and Sanders say.

Remember New Time Parameters; Forget 99201

Next year, you’ll apply these rules about time-based reporting to E/M codes 99202 (Office or other outpatient visit for the evaluation and management of a new patient, which requires these 3 key components: An expanded problem focused history; An expanded problem focused examination; Straightforward medical decision making …) through 99215 (Office or other outpatient visit for the evaluation and management of an established patient, which requires at least 2 of these 3 key components: A comprehensive history; A comprehensive examination;

Medical decision making of high complexity). These rules do not apply to other E/M codes, such as hospital observation, hospital inpatient, etc.

The rules also don’t apply to 99201 (Office or other outpatient visit for the evaluation and management of a new patient, which requires these 3 key components: A problem focused history; A problem focused examination; Straightforward medical decision making …), as CPT^® is deleting the code next year.

Why? Since 99201 and 99202 (… An expanded problem focused history; An expanded problem focused examination; Straightforward medical decision making …) require straightforward MDM, and time and MDM are the predominant components for 2021 code selection, 99201 was redundant. Further, most providers report that they were rarely using 99201 anyway.

Check out the time parameters CPT^® will use for each E/M code in 2021 and beyond:

• 99202: 15-29 minutes.
• 99203: 30-44 minutes.
• 99204: 44-59 minutes.
• 99205: 60-74 minutes.
• 99211: Time component removed.
• 99212: 10-19 minutes.
• 99213: 20-29 minutes.
• 99214: 30-39 minutes.
• 99215: 40-54 minutes.

Use This Guide to Tally Professional Time

CPT^® will expand its definitions of encounter time in 2021 to make them align with the new code selection policy. When code selection is time-dependent, you’ll still tally the total time spent performing the service on the day of the encounter, Jimenez confirms.

The difference: CPT^® is “changing the definition of the time element associated with codes 99202-99215 from typical face-to-face time to total time spent on the day of the encounter, and changing the amount of time associated with each code,” according to Jimenez.

Scott and Sanders report that you can count these activities toward your time calculation when choosing an E/M level in 2021:

• Reviewing tests/records before seeing the patient.
• Reviewing separately obtained history.
• Performing medically appropriate exam/eval.
• Counseling/educating patient/family/caregiver.
• Ordering tests or procedures, providing medications.
• Referring and communicating with other health professionals.
• Documentation of clinical information in the electronic health record (EHR).
• Independently interpreting and communicating results.
• Coordinating care.