Otolaryngology Coding Alert

Widespread CPT^® descriptor changes will impact otolaryngology coding in 2023.

Practices will be breaking in a new set of evaluation and management (E/M) guidelines for their facility visits starting in January of 2023.

Background: To standardize E/M code level determination, the AMA has made additional revisions to E/M coding for implementation next year. The updates seek to provide continuity across all the E/M sections, allowing for the changes to office and outpatient services enacted in 2021 to extend to the remainder of the E/M section of CPT^® beginning Jan. 1, 2023. The 2023 revisions to the 2021 E/M guidelines are part of the Patients Over Paperwork initiative.

“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 for an overview of what you need to know as you prepare for the changes CPT^® 2023 will bring about next year.

Review the Seismic Shift in ED Coding

CPT^® 2023 revises the five emergency department (ED) E/M codes to align with the revised the medical decision making (MDM) elements CPT^® previously introduced in 2021 with the office/outpatient E/M service codes. The new descriptors are as follows:

• 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 (… which requires a medically appropriate history and/or examination and straightforward medical decision making)
• 99283 (… low level of medical decision making)
• 99284 (… moderate level of medical decision making)
• 99285 (… high level of medical decision making)

Impact: All levels of ED service will include a medically appropriate history and examination as determined by the treating provider, but they will have no bearing on the level of service.

Familiarize yourself with these key modifications to ED E/M coding for 2023:

• When selecting a level of service in 2023, you’ll use MDM alone. E/M services in the ED will no longer be selected based on the key components of history, examination, and MDM.
• Time will not be a descriptive component for the ED levels of E/M services. This means that unlike other E/M services, the only method for choosing an E/M level in the ED is MDM; time will not be used as a factor in level selection.
• When selecting the level of an ED E/M code, you’ll use the highest two of three elements of MDM:

o Problem(s): number and complexity of presenting problems

o Data: amount and/or complexity of data to be reviewed and analyzed

o Risk: risk of complications and/or morbidity or mortality of patient management

• MDM level will not apply to code 99281 because, like code 99211 (Office or other outpatient visit for the evaluation and management … that may not require the presence of a physician …), this level of service does not require the presence of a physician or other qualified health care professional (QHP).

Impact: As medical necessity will be an overarching criterion for leveling ED E/M services, the provider will have to consider whether the nature of the presenting problem (NOPP) supports the medical necessity of services rendered.

Say Goodbye to These Observation Codes

In one fell swoop, CPT^® is getting rid of its per-day initial and subsequent outpatient hospital observation codes for services spanning over multiple dates.

What’s being scrapped? Come Jan. 1, 2023, you’ll no longer be able to report:

• 99218-29920 (Initial observation care, per day, for the evaluation and management of a patient …)
• 99224-99226 (Subsequent observation care, per day, for the evaluation and management of a patient …)
• 99217 (Observation care discharge day management …)

What should you do? Instead, you will use one of the existing inpatient hospital care codes, which have received extensive descriptor revisions, allowing you to use MDM or time to guide code selection.

• Initial observation care: 99221-99223 replaces 99218-99220
• Subsequent observation care: 99231-99233 replaces 99224-99226
• Discharge management: 99238-99239 replaces 99217

Impact: Patients admitted for observation services will be considered to have hospital outpatient observation status through the end of 2022. That designation will change to inpatient status starting in January.

This switch from outpatient to inpatient status for multi-day observation patients means that “the difficulty of classifying patients as observation or inpatient with the hospital enrollment department will be eliminated. This will eliminate a great deal of the guess work and potential denials because of status mismatches with claims as of January,” says Barbara J. Cobuzzi, MBA, CPC, COC, CPC-P, CPC-I, CENTC, CPCO, CMCS, of CRN Healthcare in Tinton Falls, New Jersey.

Note Discharge Services Moved Under 99238, 99239

Reporting discharge services will be different next year, as CPT^® created descriptors that will allow you to use one set of codes for either hospital inpatient or observation discharge day management. Check out the revamped code descriptors:

• 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)

Streamline Your Hospital and Observation Services Coding

CPT^® 2023 will retain its original initial and subsequent per-day hospital care codes, but they will be vastly different and more inclusive of observation services. Note the substantial changes in the descriptors:

• 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 (… moderate level of medical decision making … 55 minutes must be met or exceeded.)
• 99223 (… high level of medical decision making … 75 minutes must be met or exceeded.)
• 99231 (Subsequent hospital inpatient or observation care, per day … which requires a … low level of medical decision making. When using total time … 25 minutes must be met or exceeded.)
• 99232 (… moderate level of medical decision making … 35 minutes must be met or exceeded.)
• 99233 (… high level of medical decision making … 50 minutes must be met or exceeded.)

Impact: When the calendar flips to Jan. 1, 2023, you will use the above codes for all multi-day hospital inpatient and observation services. For these visits, you will choose either revised code 99238 or 99239 for discharge.

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

For the full list of 2023 E/M code and guideline revisions, go to www.ama-assn.org/system/files/2023-e-m-descriptors-guidelines.pdf.