Coming 2021- Lets make your life a little bit easier next year.
If you're like most providers documenting and coding E&M services can be a pain in the butt. Am I over coding, am I under coding, could I have coded a level higher if I would have added a little something extra to my note, did I hit a
ll of the required guidelines?? And like most specialty providers you probably don't feel like you are being reimbursed enough for the time spent reviewing reports, consulting with other providers, ordering new tests and scheduling surgeries; all of which is done outside of the patient's actual appointment time. Well it seems like CMS must agree with you!!!
For as long as you can remember, depending on your age, your level of service for reimbursement was determined by the number of elements you documented in your HPI, ROS, PMFSH and Exam along with your MDM. Starting in 2021 for Medicare, Medicare replacements and Medicaid patients your level of service will be determined by your TOTAL TIME SPENT treating the patient or your MDM. Here's the best part, it's not time spent face to face with your patient, you get to use time spent coordinating care on the date of the appointment!!
Rules and Requirements....
The new time based E&M coding guidelines only apply to outpatient office visits, these rules do not apply to inpatient, observation, ER, or critical care. Time based rules will be for code set 99202-99205, 99212-99215, 99211 & a new code that has not yet been released.
Time Spent Coordinating Care- you may include the following time in your total time spent as long as you performed these functions ON THE DATE OF SERVICE. If you review documentation/labs/testing the day before the date of service you may not include that time.
Preparing to see the patient
Obtaining and/or reviewing separately obtained history
Performing a medically appropriate examination and or evaluation
Counseling and educating the PATIENT, FAMILY OR CAREGIVER
Ordering medications, tests and or procedures
Referring and communicating with other health care professionals
Documenting clinical information in the electronic or other health record.
Independently interpreting results (not separately reportable) and communicating
results to the patient/family/caregiver
Care coordination (not separately reportable)
YOU HAVE TO DOCUMENT YOUR TOTAL TIME IN YOUR NOTE!!! If you dont you know whoever does your coding or auditing is going to come back to you and make you addend that note and what are the chances you are going to remember all of the time you spent coordinating the patients care and you are going to short change yourself. You will need to continue to document your HPI, ROS, PFSH and exam components however those will only depict your level of service for non medicare payers. Now is not the time to short yourself!!
Level and Time
Medical Decision Making-
Source: CPT is a registered trademark of the American Medical Association. Copyright 2019 American Medical Association. All rights reserved. Table 2 https://www.ama-assn.org/system/files/2019-06/cpt-office-prolonged-svs-code-changes.pdf
Let's Talk Money- CMS released a final fee schedule estimate for 2021 E&M codes. Here is how they compare the previous rates. Source: Table 24B, CMS 2019 PFS final rule; All rates are national average.
Wrap It UP
Time based E&M is going to apply to your medicare and medicare replacement plans only. Commercial plans are not required to adopt the new E&M structure and therefor your guidelines for determining the level of service for your other payers will remain the same as they previously has been. Most likely you are not aware of the patients coverage prior to evaluating them so make habit of continuing your current documentation process and add your time spent at the end of each note. Your coder will be able to level your service appropriately based on the patients payer to maximize your reimbursement.
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