Orthopedic Coding Alert

Here’s the group of observation codes that CPT^® is completely deleting.

Here we go again.

The American Medical Association (AMA) has made its changes to evaluation and management (E/M) coding for 2023 … and if you’re experiencing a bit of déjà vu, you’re not alone.

The skinny: As with office/outpatient E/M codes in 2021, the AMA is changing descriptors for (or outright deleting) several code sets in the other E/M sections 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.

Original Per-Day Observation Codes Nixed

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.”

CPT^® Moves 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 deleted? CPT^® 2023 will delete 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 add 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.

CPT^® Overhauls 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 deleted? CPT^® 2023 will delete 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 add 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, for the evaluation and management of a patient, which requires a medically appropriate history and/ or examination and moderate level of medical decision making. When using total time on the date of the encounter for code selection, 55 minutes must be met or exceeded.)
• 99223 (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 high level of medical decision making. When using total time on the date of the encounter for code selection, 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.

Get Ready for Single-Day Observation/Inpatient Service Combo Codes

CPT^® 2023 will hold onto its single-day observation codes, but they will be much different. Much like the revisions of 99221 through 99223, these revisions will make the codes more inclusive.

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

• 99234 (Observation or inpatient hospital care, for the evaluation and management of a patient including admission and discharge on the same date, 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...)
• 99235 (… A comprehensive history; A comprehensive examination; and Medical decision making of moderate complexity...)
• 99236 (… A comprehensive history; A comprehensive examination; and Medical decision making of high complexity… )

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

• 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.)
• 99235 (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 moderate level of medical decision making. When using total time on the date of the encounter for code selection, 70 minutes must be met or exceeded.)
• 99236 (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 high level of medical decision making. When using total time on the date of the encounter for code selection, 85 minutes must be met or exceeded.)

Impact: As the descriptors indicate, 99234-99236 will be your one-stop shop for one-day hospital inpatient or observation care services.

ED Code Descriptors Reflect MDM Focus

The 2023 E/M revisions will also hit reset on the code descriptors for emergency department (ED) E/M services.

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

• 99281 (Emergency department visit for the evaluation and management of a patient, which requires these 3 key components: A problem focused history; A problem focused examination; and Straightforward medical decision making...)
• 99282 (… An expanded problem focused history; An expanded problem focused examination; and Medical decision making of low complexity…)
• 99283 (… An expanded problem focused history; An expanded problem focused examination; and Medical decision making of moderate complexity...)
• 99284 (… A detailed history; A detailed examination; and Medical decision making of moderate complexity...)
• 99285 (Emergency department visit for the evaluation and management of a patient, which requires these 3 key components within the constraints imposed by the urgency of the patient’s clinical condition and/or mental status: A comprehensive history; A comprehensive examination; and Medical decision making of high complexity...)

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

• 99281 (Emergency department visit for the evaluation and management of a patient that may not require the presence of a physician or other qualified health care professional)
• 99282 (Emergency department visit for the evaluation and management of a patient, which requires a medically appropriate history and/or examination and straightforward medical decision making)
• 99283 (Emergency department visit for the evaluation and management of a patient, which requires a medically appropriate history and/or examination and low level of medical decision making)
• 99284 (Emergency department visit for the evaluation and management of a patient, which requires a medically appropriate history and/or examination and moderate level of medical decision making)
• 99285 (Emergency department visit for the evaluation and management of a patient, which requires a medically appropriate history and/or examination and high level of medical decision making)

Impact: E/M coding in the ED just underwent a seismic shift. Rather than focus on the “three key components” that used to govern ED E/M code choice, coders will have to use medical decision making (MDM) as the sole determinant of code level in 2023 and beyond.