Overview of the 2021 E/M Guideline Coding Changes
Practices have not seen many revisions to the Evaluation and Management (E/M) office / outpatient visit guidelines in three decades – until now. As of January 1, there are new E/M coding guidelines. We’ll get to those in a bit, but first let’s look at why they changed.
Prior to the 2021 updates, the E/M Coding Guidelines:
…were outdated. Here’s a timeline:
- 1992 – Evaluation and Management codes published in the CPT code book
- 1995 – 1st set of guidelines (1995 Guidelines) published to help quantify E/M codes
- Not supported by specialty providers due to the level of exam – 8 systems is needed for a comprehensive exam
- 1997 – Guidelines published to meet the needs of specialty providers. ED and Family Practice providers found them too cumbersome so CMS decided either set could be used
- 2021 – In 2019 CPT Editorial Panel and RUC workgroup developed new guidelines for 2021
…fostered EHR misuse, namely cloned documentation.
- Medicare (CMS), defines cloned documentation as “multiple entries in a patient’s health record that are exactly alike or similar to other entries in the same patient’s health record or another patient’s health record” (CMS, n.d.) Terms used for duplicative documentation also includes cloning, copy and paste, copy forward, macros, and save notes as a template.
- Document to meet bullet points
- Advancement in medical care
…allowed more opportunity for upcoding.
- Payer audits
- CERT Program
- Historical data skewed
- Patient visit frequency
- Note bloat
It’s pretty clear things needed to change. Here’s what’s new in the 2021 E/M Guidelines:
- 99201 – Deleted
- 99202/99212 – Straightforward
- 99203/99213 – Low
- 99204/99214 – Moderate
- 99205/99215 – High
Places of service that will NOT be impacted:
- Hospital Observation
- Hospital Inpatient
- Consultations, Emergency Department
- Nursing Facility, Domiciliary
- Rest Home or Custodial Care and Home E/M Services
Guidelines that will NOT change:
- Definition of New vs. Established Patient
- Appropriate clinical Documentation
- All other E/M Services and calculations
- Incident To Guidelines
- Split Shared Services Guidelines
- Modifier 25
Guidelines that WILL change:
- Removal of history and exam as key components in code selection
- Select the category or subcategory of service and review the guidelines
- Review the level of E/M service descriptors and examples
- Determine level of MDM
- Select appropriate level of E/M service
- Code selection is based on:
- Time may be used to determine the level of services
- Office or other outpatient services: total time can be the determining factor in the E/M level assignment.
- Other E/M service subcategories: time may only be used for selecting the level of other E/M service categories when counseling and/or coordination of care dominate the service.
- Medical Decision Making
- The amount or complexity of data to be reviewed and analyzed.
- Risk of complications or morbidity of patient management can now include social determinants of health
- Quantifies the numbers of tests ordered, tests reviewed, and/or notes and records reviewed
…and that’s just the start of it. Click here to learn more and be sure to sign up to be notified about our webinar where we will review the most common challenges to date with the new 2021 E/M Coding Guidelines.
Here is what our HIA coding experts are seeing during reviews:
“Providers may be able to save some time by documenting a medically appropriate history and exam instead of following the old requirements for those components.”
“Ensuring that labs/tests are not credited multiple times when the labs/tests are ordered at one visit and analyzed at the next visit could be problematic.”
“Providers could be missing out on medical decision-making elements by not documenting things like obtaining information from an independent historian or social determinants of health that could affect treatment.”
“With the removal of credit for a new problem with or without workup under amount and/or complexity of data, it is important the providers fully document their cognitive labor for the visit to obtain credit for all the work required to diagnosis a new problem.”
“For providers who see patients in both inpatient and outpatient settings, the challenge for them is to remember which set of rules applies and to document accordingly.”
“The AMA has provided some clarification for some of the medical decision-making definitions. Assigning the appropriate level will depend on provider documentation so review of the AMA MDM definitions is very important.”
Anticoagulants and antiplatelets are used for the prevention and treatment of blood clots that occur in blood vessels. Oftentimes, anticoagulants and antiplatelets are referred to as “blood thinners,” but they don’t actually thin the blood at all. These drugs slow down the body’s process of making clots. Their main function is to keep the patient’s blood from clotting or turning into solid clumps of cells. These drugs do this by interfering with either fibrin or platelets in the blood.
Carotid artery disease is a vague category that can incorporate many different carotid artery issues. Some physicians may feel that they are being clear the patient has plaque, stenosis, or occlusion of the artery, but in ICD-10-CM the specificity must be included in the documentation.
10 ICD-10 Codes for Superheroes. Superman: T78.2XXA Anaphylactic reaction; substance: kryptonite. Batman: F44.81 Dissociative identity disorder. Robin: F60.7 dependent personality. The Hulk: L30.4 Erythema intertrigo. Wonder Woman: T24.032A Burn of unspecified degree of left lower leg. Black Panther S93.401A Sprain…
Pseudoseizures are a form of non-epileptic seizure. These are difficult to diagnose and oftentimes extremely difficult for the patient to comprehend. The term “pseudoseizures” is an older term that is still used today to describe psychogenic nonepileptic seizures (PNES).
With the implementation of ICD-10-CM came different codes and coding rules for many diagnoses. One of these is the coding of bowel obstruction when the patient presents for this condition that is caused by another condition.
This is Part 5 of a five part series on the new 2021 CPT codes. For the remaining areas we will just briefly summarize the section. Due to the intricate nature of these sections in CPT, it is recommended that the coder read the entire section notes associated with the new codes.
This is Part 4 of a five part series on the new 2021 CPT codes. In this series we will explore the CPT changes in the urinary, nervous, ocular and auditory systems. There are 2 new urinary/male reproductive system codes with no revisions or deletions; 3 new female reproductive codes with 2 deletions, 0 new with 4 deleted nervous system codes with 5 revisions; 5 new eye category III codes; and finally a 2 new auditory codes with one deletion.
This is Part 3 of a five part series on the new 2021 CPT codes. In this series we will explore the cardiovascular system CPT changes. There are 5 new cardiovascular CPT codes added with 0 deletions and 4 revisions.
This is Part 2 of a five part series on the new 2021 CPT codes. In this series we will explore the CPT changes for FY2021 and include some examples to help the coder understand the new codes. There are 0 new musculoskeletal CPT codes added with 0 deletions and 2 major revisions along with an extensive update to arthroscopic loose body removal requirements. For the respiratory system, there were 2 new codes, one code deletion and no revisions.
This is Part 1 of a five part series on the new 2021 CPT codes. In this series we will explore the CPT changes for FY2021 and include examples to help the coder understand the new codes. For 2021 in general, there were 199 new CPT codes added, 54 deleted and 69 revised.
In January, new CPT codes were released. There were 248 new CPT codes added, 71 deleted and 75 revised. Most of the surgery section changes were in the musculoskeletal and cardiovascular subsections. These included procedures such as skin grafting, breast biopsies, deep drug delivery systems, tricuspid valve repairs, aortic grafts and repair of iliac artery.
We have seen many updates and changes to COVID-19 (SARS-CoV-2) since the pandemic started. On January 1, 2021 we will see even more changes as outlined in this post. Also the CMS MS-DRG grouper will be updated to version 38.1 to accommodate the changes.
In the previous three parts of this four-part series, we discussed the new ICD-10-CM diagnosis code changes, ICD-10-PCS procedure code changes and FY2021 IPPS changes. In this last Part 4 of the series, we will review the NTAP procedure codes and reimbursement add-on payments for FY2021.
In the previous two parts of this four part series, we discussed the new ICD-10-CM diagnosis code changes and ICD-10-PC procedure code changes. In this session we will review the major IPPS changes for FY2021.
This is Part 2 of a 4 part series on the FY2021 ICD-10 Code and IPPS changes. In this part, the ICD-10-PCS procedure codes are presented. For FY2021 ICD-10-PCS there are 78,115 total codes (FY2020 total was 77,571); 556 new codes (734 new last year in FY2020)…
This is Part 1 of a 4 part series on the FY2021 changes to ICD-10 and the IPPS. In this part, we discuss some of the new ICD-10-CM diagnosis changes. Here is the breakdown: 72,616 total ICD-10-CM codes for FY2021; 490 new codes (2020 had 273 new codes); 58 deleted codes (2020 had 21 deleted codes); 47 revised codes (2020 had 30 revised codes)
Acute pulmonary edema is the rapid accumulation of fluid within the tissue and space around the air sacs of the lung (lung interstitium). When this fluid collects in the air sacs in the lungs it is difficult to breathe. Acute pulmonary edema occurs suddenly and is life threatening.
“Client S” is a small, not-for-profit, 40 bed micro-hospital in the Southeast. HIA performed a 65-record review this year for Client S and found an opportunity with 15 of them. 9 had an increased reimbursement with a total of $43,228 found.
The coma scale codes (R40.2-) can be used in conjunction with traumatic brain injury codes, acute cerebrovascular disease or sequelae of cerebrovascular disease codes. These codes are primarily for use by trauma registries, but they may be used in any setting where this information is collected. The coma scale may also be used to assess the status of the central nervous system for other non-trauma conditions, such as monitoring patients in the intensive care unit regardless of medical condition.
In the past, there had been an Excludes1 note at I46.- Cardiac arrest that excluded R57.0, Cardiac shock. HIA had also received a letter from AHA on a case in the past that had stated that only I46.- Cardiac arrest would be coded if both were documented. In addition, the Third Quarter Coding Clinic page 26 had a similar case that asked if both could be coded, and AHA had instructed that only I46.9, cardiac arrest, cause unspecified would be coded if both were documented and that the CDC would be looking at possible revision to the Excludes1 note.
A higher CMI corresponds to increased consumption of resources and increased cost of patient care, resulting in increased reimbursement to the facility from government and private payers, like CMS. We know that documentation directly impacts coding.
Lately we have seen several cases where the endarterectomy was assigned along with the coronary artery bypass (CABG) procedure when being performed on the same vessel to facilitate the CABG. A coronary artery endarterectomy is not always performed during a CABG procedure, so when it is performed it becomes confusing as to whether to code it separately or not.
Assign code Z20.828, “Contact with and (suspected) exposure to other viral communicable diseases” for all patients who are tested for COVID-19 and the results are negative, regardless of symptoms, no symptoms, exposure or not as we are in a pandemic.
One common element in many value-based programs is risk adjustment using Hierarchical Condition Categories (HCCs) to create a Risk Adjustment Factor (RAF) score. This method ranks diagnoses into categories that represent conditions with similar cost patterns.
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In previous parts of this series we looked at the definitions of AKI/ARF, causes, coding and sequencing, and the common clinical indicators that patients present with that are diagnosed with this condition. In Part 4, we will look at the documentation that should be present to report the diagnosis without fear of denial, as well as when a query is needed to clarify the diagnosis.
If the facility does a COVID-19 test, and test is negative, do I need a diagnosis code. The answer is yes, you will report a Z-code. The Z-code depends on the record documentation and circumstances of testing. For any patient receiving a COVID-19 test, if negative, there MUST e a Z-code to describe why the test was taken. (Test negative for COVID-19 and MD does not override negative results).
In the first parts of this series we looked at definitions of AKI/ARF, causes, coding and sequencing. In Part 3, we will look at what clinical indicators would possibly be present to support the diagnosis of AKI/ARF.
The FY2021 IPPS Proposed Rule is out and here are some highlights from it regarding ICD-10 Code proposals. We will know if these changes are permanent after the public comment period is over on July 10, 2020 and CMS prepares the Final Rule, usually out by August 1.