30 FAQ’s to Start Your 2021 Reporting Off RightA new year means new CPT changes have been released. These changes apply to E/M office and other outpatient visit reporting. We’ve compiled a list of 30 FAQ’s so that you can start your 2021 reporting off right. Continue reading below to learn more.

By Ginger Avery, CPC, CPMA, CRC
January 5, 2021

1.Where can the CPT E/M code and guidelines be found? The CPT E/M code and guideline changes for 2021 can not only be found on the American Medical Associations (AMA) site at this link, but they can also be found in their entirety within the 2021 CPT Code books themselves. These guidelines include the new level of medical decision-making table and the 22 new definitions that help clarify what the MDM terms mean.

2.Does pulling the lab results into the note constitute a “review of results” or do I need to document by stating that I have reviewed them? Moving forward information from old notes without comment does not add any value to the work that was performed and does not count. Did you review/analyze these results, what impact does this have on today’s visit? What is the clinical significance of this additional work?

3.When tests are ordered during one visit and reviewed the same test during the next visit, can that count as a data point for both visits? With the new guidelines, we no longer have data “points”. Both encounters would support Limited data (low) with Category 1. The first encounter supports Category 1 for ordering of the test, the follow up encounter would support Category 1 for review of the results.

4.Where does lifestyle counseling come into this? Preventive medicine counseling and/or risk factor reduction interventions (99401-99412) are time-based codes but do NOT follow the office visit E/M guidelines. Relevant visit details and total F2F time should be documented appropriately. Code selection is based on the F2F time spent with the patient.

5.When reporting for total time, is it just time spent with patient at the encounter? No, in 2021, time is defined as the total encounter time on the date of service. This includes both F2F work and non-F2F work personally performed by the clinician.

6.When dealing with complex patients where time is difficult to track will we have to revert to Medical Decision Making? With the new guidelines, you now have a choice, MDM or total encounter time. If total encounter time runs outside of the date of service or is challenging to track, then reporting based on the medical decision making may be a better choice. Do not undervalue the complexity by not documenting all the relevant work you do.

7.Seeing how we cannot estimate for time that could be spent, say for a possible follow up phone call, how should we code to earn credit for that work? Time based reporting is only appropriate for time spent on the date of the encounter. Follow up phone calls on a later date cannot be reported based on time. MDM should be considered. In column 2 of the level of MDM chart, Category 3 provides credit when discussing the case with other clinicians or appropriate source. Be sure to document these details when true.

8.Providers do use outpatient codes in the hospital if patient is in Observation status “not Inpatient”, I would assume these rules would apply to bill new/vs est pt when appropriate? Yes, the guideline updates are for office visits and other outpatient services.

9.With the new time-based reporting, it seems that we absolutely need to sign off on our notes on the day of service. This is not always feasible given a busy day. In 2021, total encounter time includes completing documentation. If a clinician is unable to complete their note on the date of the encounter, reporting based on MDM may be a better choice.

10.Some of these activities occur after the visit (complications/adverse reactions) – how can you account for that in your note for that day? Complications and adverse reactions may support an additional encounter when the need for evaluation and management may arise but would not be included on the date of the encounter unless that presentation was true during the visit.

11.Do the E/M changes apply to outpatient or inpatient services? The 2021 E/M changes only apply to Outpatient services. Inpatient visits still need to follow the key component guidelines (1995 or 1997).

12.Since history and physical exam are no longer required to level the visit, should these elements still be documented? Yes, history and exam are still part of an evaluation. The documented content should be focused on the clinically relevant details and cognitive thoughts of the clinician, not checkboxes or templated details. What is the nature of the presenting illness(es) (subject details with pertinent ROS)? Document a medically necessary exam. Documentation is about the quality of the story, not the quantity of details. Don’t import pages of past medical history or medication lists that aren’t relevant. Clinicians are encouraged to write notes that they would like to read.

13.Do I still have to document ROS and PFSH? Yes, when clinically relevant. For example: Patient presents with chest pain. Has been having intermittent chest pain at rest for two weeks. No notable triggers. Positive for headaches and dizziness, no SOB. Patient has a past family history of CAD. Remember, documentation is all about the medically necessary story.

14.When coding based on total time does the assessment and plan still need to be documented? Yes. Quality documentation should always be captured. Clinical impressions and plans that are well documented support the medical necessity for the services provided, regardless of how you choose to report the visit. Again, clinicians are encouraged to write notes that they would like to read.

15.When coding based on total time and have also provided additional time-based services (advance care planning, counseling, etc.) how should those services be documented? The time associated with each visit should be separate and clearly identified to support each unique service.

16.Are commercial plans required to adopt the revisions to E/M codes? Yes. The CPT code set, together with the U.S. Department of Health and Human Services’ Healthcare Common Procedure Coding System, has been adopted as the nation’s standard medical data code set. HIPAA requires that health plans use the most recent version of the medical data code set, they should be ready to implement the revisions Jan. 1, 2021.

17.Who else besides clinicians needs to implement the 2021 E/M office visit changes? Other clinicians, coders, third-party plan administrators, and other health care-related entities should start using the revised code set Jan. 1. Physician practices should confirm that their contracted health plans and EHR vendors are integrating the revised codes into their software systems and will be ready Jan. 1, 2021.

18.Can I still use my EHR’s coding calculator? Technically, Yes. It is important that clinicians confirm with their EHR vendor that their system’s code-selection application conforms to the revised codes and descriptors because the billing provider has the ultimate responsibility for appropriate coding. The EHR’s coding calculators are simply bean counters driven by templates and checkboxes; medically necessity cannot be quantified utilizing a point counting system. Often these systems are not set up with the appropriate guidelines and do not include additional instruction.

19.Can we still bill 99201-99205 and 99211-99215 based on the 1995 and 1997 guidelines for dates of service on and after January 1, 2021? Office/outpatient visits PRIOR to January 1, 2021 may still be billed using the 1995 or 1997 guidelines. Clinicians must bill office/outpatient visits provided ON or AFTER January 1, 2021 using the CPT E/M code and guideline changes for 2021. Note: Based on the CPT changes, code 99201 is no longer valid for dates of service on and after January 1, 2021.

20.Do the 2021 E/M code and guideline changes apply to all categories of E/M services? No. The E/M code and guideline changes are specific for office and other outpatient visits and apply only to codes 99201–99205 and 99211–99215.

21.For dates of service on and after January 1, 2021, how are the levels of E/M services provided in an office/outpatient setting determined? For dates of service on and after January 1, 2021, select the appropriate level of E/M service based on the following (you choose): The level of the medical decision making as defined for each service; OR the total time personally spent by the clinician for all services related and dedicated to that patient on the date of the encounter.

22.Does the revised medical decision-making table for 2021 provided by the AMA apply to all E/M services? No. The CPT E/M code and guideline changes for 2021 and subsequent MDM table only apply to office/outpatient E/M services beginning January 1, 2021. All other E/M categories and codes continue to follow the 1995 and/or 1997 E/M guidelines. However, the additional clarification provided in the new guidelines displays the importance of documenting clinically significant details (medically necessary), avoiding templated checkbox information and provides definitions for many of the terms on the table of risk to help the reader understand appropriate considerations of Medical Decision Making.

23.Is the documentation of history and examination required when scoring office/outpatient services under the revised 2021 guidelines? The approved revisions do not materially change the three current MDM elements, but instead provide extensive edits to the elements for code selection and revised or created numerous clarifying definitions in the E/M guidelines. While the provider’s work in capturing the patient’s pertinent history and performing a relevant physical exam contributes to both the time and medical decision making, these elements alone should not determine the appropriate code level. The revised code descriptors state a “medically appropriate history and/or examination” is required.

24.Is time defined differently for office and outpatient E/M services effective for dates of service on and after January 1, 2021? According to the AMA, for dates of service on and after January 1, 2021, time is defined as minimum time, not typical time, and represents the total encounter time personally spent by the clinician on the date of service. This definition applies only when code selection is based on time and not MDM.
Is time defined differently for office and outpatient E/M services effective for dates of service on and after January 1, 2021? According to the AMA, for dates of service on and after January 1, 2021, time is defined as minimum time, not typical time, and represents the total encounter time personally spent by the clinician on the date of service. This definition applies only when code selection is based on time and not MDM.

25.When coding by time, is the day of encounter by calendar date or 24-hour period? When coding by time, only the time spend on the actual calendar date of the encounter is applicable.

26.How is time counted under the CPT E/M code and guideline changes for 2021? Except for code 99211, per AMA, beginning with CPT changes 2021, time alone may be used to select the appropriate code level for the office or other outpatient E/M service codes (99202-99205, 99212- 99215). Time may be used to select a code level in office or other outpatient services regardless or not counseling and/or coordination of care dominates the service. When time is used to select the appropriate level for E/M service codes, time is defined by the service descriptors. The E/M services for which these guidelines apply require a face-to-face encounter with the clinician. For office or other outpatient services, if the clinician’s time is spent in the supervision of clinical staff who perform the face-to-face services of the encounter, use code 99211.

27.What activities can be counted towards total clinician time? Time includes the following activities when personally performed by the clinician:

  • Preparing to see the patient (e.g., review of tests).
  • Obtaining and/or reviewing separately obtained history.
  • Performing a medically appropriate examination and/or evaluation.
  • Counseling and educating the patient/family/caregiver.
  • Ordering medications, tests, or procedures.
  • Referring and communicating with other health care professionals (when not separately reported).
  • Documenting clinical information in the electronic or other health record.
  • Independently interpreting results (not separately reported) and communicating results to the patient/family/caregiver.
  • Care coordination (not separately reported).

28.How do other requirements (e.g., teaching physician, incident to, new vs. established) apply when using the CPT E/M guidelines for 2021? CMS is adopting the AMA’s guidance on coding office/outpatient E/M visits. Most rules remain unchanged.

29.Can the independent visualization of a test be counted in the medical decision making if the physician is also billing for the test? Per AMA, the actual performance and/or interpretation of diagnostic tests/studies during a patient encounter are not included in determining the level of E/M service when reported separately. Clinician performance of diagnostic tests/studies for which specific CPT codes are available may be reported separately, in addition to the appropriate E/M code. The clinician’s interpretation of the results of diagnostic tests/studies (i.e., professional component) with preparation of a separate distinctly identifiable signed written report may also be reported separately, using the appropriate CPT code and, if required, with modifier 26 appended. If a test/study is independently interpreted in order to manage the patient as part of the E/M service but is not separately reported; it is part of medical decision making.

30.When considering High Risk MDM, there is an example listed: “drug therapy requiring intensive monitoring for toxicity”. What constitutes supporting this definition? When considering this complexity, both the drug and the monitoring must qualify. The new guidelines provide this definition when considering this High Risk example: “Drug therapy requiring intensive monitoring for toxicity: A drug that requires intensive monitoring is a therapeutic agent that has the potential to cause serious morbidity or death. The monitoring is performed for assessment of these adverse effects and not primarily for assessment of therapeutic efficacy. The monitoring should be that which is generally accepted practice for the agent but may be patient specific in some cases. Intensive monitoring may be long-term or short term. Long-term intensive monitoring is not less than quarterly. The monitoring may be by a lab test, a physiologic test or imaging. Monitoring by history or examination does not qualify. The monitoring affects the level of medical decision making in an encounter in which it is considered in the management of the patient. Examples may include monitoring for a cytopenia in the use of an antineoplastic agent between dose cycles or the short-term intensive monitoring of electrolytes and renal function in a patient who is undergoing diuresis. Examples of monitoring that does not qualify include monitoring glucose levels during insulin therapy as the primary reason is the therapeutic effect (even if hypoglycemia is a concern); or annual electrolytes and renal function for a patient on a diuretic as the frequency does not meet the threshold.”

As a reminder, documentation is about painting a clear picture of today’s encounter. The power of storytelling is evident with these new revisions. Quality documentation (not quantity or checkboxes) provides details to support the medical necessity and appropriate complexity of each unique encounter, as well as improves overall patient care and clinical outcomes. Clinicians are encouraged to focus their energy and documentation on the cognitive clinically relevant details, regardless of the clinical setting. Document what you do, code what you document.

RT Welter provides robust coding and documentation training for these updates, as well as other topics. Please contact cwhitworth@rtwelter.com to book your training now.

AMA CPT® E/M Code and Guideline Changes for 2021
Novitas E/M Documentation Requirements
Noridian E/M Documentation Requirements