08 Nov CMS Finalizes E/M Changes for 2021

The Centers for Medicare & Medicaid Services (CMS) released new Medicare rules last week. The final decision carries several changes in Medicare’s approach to evaluation and management (E/M) services, slated to take effect in 2021.

As we reported in August, CMS reversed course on their earlier proposal to collapse office visit E/M levels from five to two.

That decision was finalized in this recent rule, and the agency agreed to retain the existing 5 office visit levels for established patients (levels 99211-99215), while reducing the number of levels to 4 for new patients (levels 99202-99205).

Additionally, CMS adopted the AMA’s CPT Editorial Panel’s recommendations regarding the times and medical decision making (MDM) process for all levels.

Beginning in 2021, the history (HPI) and physical exam should only be performed and documented as medically appropriate, and these two elements of a visit will no longer be considered as factors when determining a level of service (no more counting body areas!)

Instead, an E/M level will be based on either documented MDM, or the time spent with the patient, if greater than 50% of the face-to-face time of the visit is spent in counseling or coordination of care. If the visit level is based on time, the documentation must include descriptions of the counseling or care coordination activities performed.

Finally, CMS agreed that physicians, physician assistants, and advanced practice registered nurses can review and verify documentation by other physicians, residents, medical, physician assistant, and APRN students, nurses, or other members of the care team rather than needing to re-document.

The agency claims that these changes will save clinicians 2.3 million hours per year in burden reduction, which remains to be seen, but on behalf of our physician clients, we remain hopeful.

To see more detail about these updates, and others released by CMS, their fact sheet is available HERE.

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