February 5, 2021 | By Paul Spencer, CPC, COC
As coders, auditors, and practitioners, we now find ourselves one month into the new world of outpatient evaluation and management (E/M) services.
By now, certain patterns are hopefully beginning to emerge with regard to providers’ E/M documentation. As templates change and providers make the choice between basing their E/M level selection on medical decision making or total time (or perhaps switching between them based on circumstances), practices should notice something of a normalized pattern revealing itself with regard to the timely completion of documentation.
Yet patterns of completion are only one aspect of the new paradigm. For all practices affected by the E/M changes, perhaps the most important information about this new world will be found in the analysis of billing trends for outpatient E/M services.
If your practice isn’t in the habit of analyzing the overall reporting of your services, whether they be E/M or other procedures or services, 2021 is the year that this task should begin in earnest. In addition to the immediate need of analyzing 2021’s shifting E/M utilization patterns in real-time, the analysis of data should be part of any meaningful practice compliance plan. A compliance plan’s main function is to mitigate risk. Thus, the consistent analysis of reported codes should be a part of risk mitigation.
As it applies to the 2021 E/M changes, the best place to begin is with your practice’s billing data from the fourth quarter of 2020. It is an oft-used maxim that in order to know where we’re going, we must be aware of where we’ve been. Breaking down reporting data from this past quarter provides a baseline that shows where your practice stood before the 2021 E/M changes took effect.
If you have this important benchmark in hand, you can use it to compare your 2021 E/M billing patterns against. Depending on how much or how little your providers have changed their documentation behaviors in this new world of outpatient E/M guidelines, any sudden shifts in code selection patterns should be viewed critically from a compliance perspective and should factor prominently into your immediate E/M audit plans. For example, if your provider is suddenly reporting more high-level codes such as 99214 and 99215 in the first quarter of 2021, you will want to audit and analyze the documentation behind those sudden increases to ensure they are compliant with the new 2021 guidelines.
Finding normalcy with the new 2021 E/M guidelines takes a multidisciplinary approach. Data analysis is only one part of this approach, but it is crucial because its results will guide your subsequent auditing and compliance decisions.
