Evaluation and Management – Beyond COVID-19 | FTI Consulting

Evaluation and Management – Looking Beyond COVID-19

Corporate Finance & Restructuring | Healthcare & Life Sciences

October 28, 2020

Stethoscope and calculator

Now that the initial wave of COVID-19 has passed and providers have mastered the telehealth billing requirements, it is time to turn attention to the 2021 Evaluation and Management (E&M) changes and their impact on a provider’s practice. Much of what was learned during the Public Health Emergency (PHE) will aid physicians as they transition to the “new” E&M requirements. However, there are still significant changes on the horizon that require attention for a practice to function efficiently and compliantly.

The 2021 E&M changes apply only to the office and outpatient (99201-99215) series of codes.1 The changes incorporate moving to a code assignment based on either time or medical decision-making (MDM). Sound familiar? This concept was introduced for use with telehealth during the Public Health Emergency (PHE) using the time increments provided in the Current Procedural Terminology (CPT) and the existing model of medical decision-making found in the 1995 E&M Guidelines. The 2021 E&M changes utilize new (longer) total time increments and a new matrix/methodology for MDM.2

The 2021 guidance is a work in progress, but some of the published highlights are as follows:3

  • The new guidance applies only to the 99202-99215 series will need to be cognizant that the requirements differ from site to site.
  • Code 99201 (office or outpatient visit requiring a problem focused history and physical with straightforward medical decision-making) is being deleted.
  • Code selection will be based upon either time or medical decision-making. No longer does the amount of history/physical examination documented affect the level of service. However, a medically appropriate and/or necessary history and exam are required, which is determined by provider.

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