March 26, 2021 | By Grant Huang, CPC, CPMA
If you thought some of the language in the 2021 E/M guidelines was confusing, you’re not the only one: The AMA has gotten enough questions about its new guidelines to issue a six-page document packed with clarifications and corrections. The document also includes an additional three pages devoted to updating vaccine product codes
The full document takes the form of a new entry to CPT 2021’s Errata and Technical Corrections, though the revisions to the E/M guidelines for office/outpatient codes (99202-99215) are unusually extensive. They focus on the sections that alter the scoring of medical decision-making (MDM) from the longstanding 1995/1997 guidelines. Below are some highlights of the clarifications:
- Some activities do NOT count toward E/M time. When selecting an E/M code level using time, you may not count time spent performing other separately reported services, or travel time, or general teaching time not related to discussion of the specific patient case for which you are reporting the E/M code.
- You CAN get ordering or reviewing credit for tests that do not require separate interpretation. Tests that do not require separate interpretation (e.g., tests that are results only) and are analyzed during the E/M visit cannot be credited for independent interpretation but can be credited for ordering/reviewing for MDM purposes, regardless of whether or not they were separately billed. The AMA also explicitly states that pulse oximetry is not considered a test for MDM data purposes.
- Condition risk is not the same as management risk. The term “risk” used under Number and Complexity of Problems Addressed is distinct from the term “risk” as applied to Risk of Complications and/or Morbidity or Mortality of Patient Management. However, presenting problems (scored under Number and Complexity of Problems Addressed) may “drive” MDM if they are likely signs of a highly morbid condition, even when the final diagnosis is not highly morbid.
- Clarifications on unique tests. When multiple results of the same test are compared, it counts as one unique test. Tests with overlapping elements are not unique, even if those elements have distinct CPT codes (e.g., a CBC with differential includes the set of hemoglobin, CBC without differential, and platelet count).
There’s quite a bit more to unpack in the document, and NAMAS is continuing to analyze the full text to better understand what they mean for coding and auditing.
If the new language hasn’t quite clarified everything for you, NAMAS hosted a special free webinar on the AMA’s 2021 E/M Technical Corrections that can be accessed at https://namas.co/2021-changes (Please note: no CEUs are available for this webinar. Webinar is for educational purposes only). This round of corrections may not be the last we receive from the AMA, but they do provide more answers – especially when it comes to the data element of medical decision making, the quantification of highly morbid conditions, and more. We encourage you to watch this important and valuable free webinar session, which will review all of these changes in detail.