The AMA’s proposals met a shared goal with CMS, putting patients over paperwork and improving our health system.
Doctors will have a simpler documentation process and additional capacity for time with patients in 2021, as a result of a revamp of Medicare coding standards for outpatient evaluation and management (E/M) services. With these revisions, physicians will only document information that is necessary or relevant to the management of their patients.
“There is a lot for physician practices to understand before the new E/M office visit guidelines take effect Jan. 1, 2021,” says AMA President Susan R. Bailey, MD. This is especially true of the effect of E/M services changes in provision of cognitive care.
Between the summer of 2018 and July 2019, the American Medical Association collaborated with the Centers for Medicare & Medicaid Services, bringing together representatives from specialty societies. Their goal was to make documentation and coding for evaluation-and-management services office visits more accessible, improve their clinical relevance, and lowering the amount of administrative effort/labor. CMS clarified in the most recent proposed Medicare physician payment schedule that these changes and new reimbursement rates take effect January 1.
Record-keeping for E/M office visits will flow from doctors’ thoughts and considerations for patients, rather than rigid codification. Prior coding regulations only resulted in boilerplate text and box-checking.
Changes to E/M Services for 2021
- Eliminate history and physical exam as elements for code selection
- Allow physicians to choose whether their documentation is based on Medical Decision Making (MDM) or Total Time
- Modifications to the criteria for Medical Decision Making
- Deletion of CPT Code 99201
- Creation of a shorter “prolonged services” code
- Physicians can decide whether to code by “total time” — including non–patient facing activities — or medical decision-making related to a visit
Because of federal budget neutrality regulations, proposed increases in some visits require cuts in others.
“Unfortunately, these office-visit payment increases, and a multitude of other new CMS-proposed payment increases, are required by statute to be offset by payment reductions to other services, through an unsustainable reduction of nearly 11% to the Medicare conversion factor,” said Dr. Bailey.
2021 E/M Changes and Cognitive Care, Plus Telehealth
Fortunately, the 2021 E/M changes don’t seem to have negatively affected reimbursement for cognitive healthcare using BrainCheck. We still recommend billing for CPT 96138/CPT96136 and CPT 9632 separately from an E/M visit. However, providers and practices should discuss all reimbursement matters will their billing coding specialists.
“Prolonged service of less than 15 minutes beyond the first hour or less than 15 minutes beyond the final 30 minutes is not reported separately. Do not report 99358, 99359 for time without direct patient contact reported in other services such as care plan oversight services (99339, 99340, 99374-99380), chronic care management by a physician or other qualified health care professional (99491), home and outpatient INR monitoring (93792, 93793), medical team conferences (99366-99368), interprofessional telephone/internet/electronic health record consultations (99446-99452), or on-line digital evaluation and management services (9X0X1, 9X0X2, 9X0X3).”