Evaluation and management coding: Dizzying rounds of changes continue to filter through

Mar 31, 2020


In an effort to combat the “note bloat” culture, the Centers for Medicare and Medicaid Services (CMS) made changes to the evaluation and management (E/M) office visit codes for 2020. This culture is largely a result of the “check-box” nature of trying to meet documentation requirements. The changes eliminated requirements for clinicians to re-record elements of history and physical exam when there is evidence that the information has been reviewed and updated, and affected codes 99201–99215.

More changes to office E/M codes are in store for 2021, including revisions to CPT (Current Procedural Terminology) code descriptors and code selection criteria. Below are some highlighted changes that have occurred and others that are anticipated:

  • Elimination of history and physical as elements for code selection: While the physician’s work in capturing the patient’s pertinent history and performing a relevant physical exam contributes to both the time and medical decision-making (MDM), these elements alone should not determine the appropriate code level. The code descriptors were revised to state that providers should perform a “medically appropriate history and/or examination”
  • Permission for physicians to choose whether their code selection is based on medical decision-making (MDM) or total time: The three current MDM components are not anticipated to change materially. However, there will be extensive edits to the elements for code selection and revised definitions in the E/M guidelines. Additionally, for both new and established patients, only two out of three components will be required. The definition of time will be total time, not typical time, and represents total physician and/ or qualified healthcare professional (QHP) face-to-face and non-face-to-face time on the date of service. These definitions only apply when code selection is primarily based on time and not MDM
  • Deletion of CPT code 99201
  • Creation of a shorter prolonged service code: This new add-on code would be reported for an additional 15 minutes of physician/QHP face-to-face and non-face-to-face time on the date of the encounter and only reported with 99205 or 99215 when time is used for code selection.

In addition, major changes to the reimbursement for these E/M office codes have been proposed.

Significant shifts within the Medicare system, such as these proposed changes for E/M reimbursement, will have a ripple effect throughout the entire Medicare system. Due to Medicare budget neutrality, there will be major shifts in total specialty payments, not just to E/M services.

While aspects of these changes will serve vascular surgeons well (i.e., reduced documentation requirements, MDM clarification, etc.) SVS is gravely concerned with the potential impact on overall vascular surgery reimbursement.

SVS has been actively engaged with CMS, the American Medical Association’s CPT/RUC (RVS Update Committee) E/M Workgroup, the American College of Surgeons and the Surgical Coalition to advocate for fair and appropriate guidelines and reimbursement for the services we provide to our patients. We are working to adjust the current proposals to more accurately align payments with the resources consumed.

Vascular surgeons should learn more about the anticipated 2021 changes to office E/M coding and prepare their practices for change. Will your Electronic Health Record system be ready? Will your coders be ready? Will your budget be ready?

The Society for Vascular Surgery (SVS) will keep the members informed of changes. Questions? Contact the SVS Coding Committee at mmalek@vascularsociety.org.

Matthew Sideman (chair) and Sunita Srivastava are members of the SVS Coding Committee.

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