CPT Editorial Panel approves sweeping changes to E/M coding and documentation guidelines

The American Medical Association’s (AMA) CPT Editorial Panel approved significant changes to E/M reporting guidelines, including the deletion of a visit code, creation of new criteria for the selection of a visit level, and overhaul of the medical decision-making (MDM) documentation guidelines at a meeting held in February, to align with recent E/M changes finalized by CMS.

The CPT Editorial Panel convenes three times per year to solicit input from practicing physicians, medical device manufacturers, and other qualified healthcare professionals on suggested updates to the CPT Manual. Members of the panel either approve, deny, withdraw, or postpone suggested coding and documentation changes. The AMA doesn’t finalize approved changes until just prior to the CPT code set’s publication, after reviewing submitted comments on the changes from interested parties.

The association is currently seeking comments through March 25 on the following E/M changes approved by panel members at the February meeting:

1. Deletion of level 1 office new patient E/M code 99201 (office or other outpatient visit for the E/M of a new patient requiring three key components: A problem-focused history, problem- focused examination, straightforward medical decision-making).
2. Removal of history and exam as key components for selection of an E/M service level. Providers would be required to document that these elements were performed in order to report visit codes 99202-99215.
3. Providers would base code selection either the level of MDM performed, or the total time spent performing the service on the day of the encounter. The definition of the time element associated with codes 99202-99215 will also change from “typical face-to-face time” to “total time spent on the day of the encounter.” This will change the amount of time associated with each code.
4. Re-organization of the E/M guidelines into three sections:
   • Guidelines common to all E/M services
   • Guidelines specific to E/M services in the facility setting, including observation, hospital inpatient, consultations, ED, nursing facility, domiciliary, rest home or custodial care, and home settings.
   • Guidelines specific to office and other outpatient visits
5. Restructure of the MDM documentation guidelines to emphasize the complexity of the conditions being addressed rather than the number of diagnoses reported.

For more information on the above updates and other approved changes, and instructions on submitting written comments, see the AMA CPT website.