E/M Documentation and Coding Changes for 2024

Medical Coding
Billing statement for medical service in doctor's office background

On November 2, 2023, the Centers for Medicare and Medicaid Services (CMS) released final rules for the 2024 Physician Fee Schedule and Hospital Outpatient Prospective Payment System and Ambulatory Surgical Center Payment System. The agency opted to cut physician pay by 1.25% and lower the conversion factor by 3.4% to $32.74 this year. This decision has been met with overwhelming opposition by physician organizations and particularly spine and orthopedic surgeons. Below, we’ve highlighted some of the most prominent changes your medical organization should be aware of. 

Multiple Same-Day E/M Visits

CPT codes 99202-99205 and 99212-99215 for office visits have been amended to remove the time range in minutes from each code. Instead, clinicians will be required to meet or exceed a “minimum time threshold” with respect to billing. 

Code2023 range of total time on date of encounter to meet (minutes)2024 minimum of total time on date of encounter to meet or exceed (minutes)

The E/M changes include new guidelines for multiple same-day E/M visits in hospital and nursing facility settings. When multiple visits occur in the inpatient hospital, observation, and/or nursing home over the course of a single calendar date, a single service is recorded. In other words, time should not be counted twice, also known as “double dipping”, for more than one E/M service on the same day. 

If a patient is discharged and readmitted to the same facility on the same day, this is considered a single visit for E/M reporting purposes. However, if they are discharged and readmitted to a different facility on the same day, two visits may be reported. 

For patients seen in the office and facility on the same day, clinicians have two options for code level selection. When using MDM for code level selection, clinicians should use the aggregated MDM over the course of the calendar date. Conversely, when using time for code level selection, clinicians should sum the time over the course of the day in accordance with reporting guidelines. 

Hospital Inpatient or Observation Care Services

Prior to 2024, the CPT codebook did not speak to the length of stay or amount of time required to report separate inpatient or observation E/M services codes and/or discharge management E/M codes. New guidelines were added to provide instructions on when it is appropriate to report codes 99234, 99235, and 99236 (for admission and discharge on the same day). These codes can only be reported by a provider who performs both the initial and discharge services on a single day and when the patient stay exceeds 8 hours. 

When a patient receives hospital inpatient or observation care lasting fewer than 8 hours, only codes 99221-99223 may be reported. For patients admitted to hospital inpatient or observation care and discharged at a later date, the appropriate level of hospital E/M service is reported on the initial day and the appropriate discharge service is reported on the subsequent day. It should be noted that discharge services can ONLY be reported by the discharging provider. 

Split or Shared E/M Visits

For shared or split E/M services, the new CPT guidelines have adopted the CMS concept of calculating which team member reports the visit based on the substantive portion. If code selection is based on total time, the provider who spends the majority or more than half of the face-to-face or non-face-to-face time with the patient will report the service. On the other hand, with medical-decision making (MDM), whoever performs the problems addressed and risk portions of the visit reports the service.  

Other Notable Changes

  • Marriage and family therapists (MFTs) and mental health counselors (MHCs) are considered providers
  • Addiction counselors or drug and alcohol counselors who meet the applicable requirements are also considered providers
  • New HCPCS codes have been established for psychotherapy for crisis services (HCPCS codes G0017 and G0018) that are furnished in an applicable site of service (any place of service at which the non-facility rate for psychotherapy for crisis services applies, other than the office setting).
  • New codes of been added to the list of Medicare telehealth services, including CPT codes 0591T – 0593T for health and well-being coaching services (on a temporary basis) and HCPCS code G0136 for Social Determinants of Health Risk Assessment (on a permanent basis). 
  • The O/O E/M visit complexity add-on code G2211 has been assigned an “active” status indicator to better account for additional resources of office and outpatient (O/O) E/M visits for primary care and longitudinal care. G2211 is not restricted to medical professionals based on specialties.

Any regulations, policies, or guidelines discussed in this article are subject to change at any given time. For more information, please refer to the CMS website. 

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