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CMS E/M Guidelines 2022

On November 2, 2021, the Centers for Medicare and Medicaid Services (CMS) released a final rule updating payment policies and rates for physicians paid under the Medicare Physician Fee Schedule (PFS) and other Medicare Part B issues in 2022. For the first time in nearly 30 years, CMS has significantly revised the Evaluation and Management (E/M) coding guidelines used for the “Office or Other Outpatient Services” category.

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The calendar year (CY) 2022 PFS final rule is one of the several rules that reflect a broader Administration-wide strategy to create a healthcare system with better accessibility, quality, affordability, empowerment, and innovation. The changes are effective as of January 1, 2022.

E/M Changes in 2022

The three biggest changes to the 2021 E/M guidelines are as follows:

New patient E/M codes (99202-99205) and established patient E&M codes (99212-99215) no longer require the three components or time for counseling and coordination of care. Instead, a medically appropriate history and examination are required, but the code selection is determined by the level of medical decision-making (MDM) or total time spent on the day of the encounter date.

  • History and physical examination are required but not used as elements for code selection.
  • Physicians may now choose to base their documentation on medical decision-making (MDM) OR the total time spent on the day of the encounter.
  • Modification of the MDM criteria that are most relevant to the office visit setting.

Time Component Coding Updates

Time descriptions and the number of minutes for each code have increased for the total time component. Total time includes all time spent on the day of the encounter for services that are not separately reported, either by the physician or other qualified healthcare professional. This encompasses both face-to-face and non-face-to-face time. Examples include, but are not limited to: 

  • Preparing to see the patient
  • Obtaining and reviewing the separately obtained history
  • Counseling and educating the patient, family, and caregiver
  • Ordering medications, tests, or procedures
  • Preparation to see patient-reviewing test results and obtained history

According to the E/M changes in 2022, medical decision-making includes establishing diagnoses, assessing the status of a condition, and selecting a management option. Previous E/M guidelines required providers to document MDM as either:

  • Straightforward (CPT codes 99212 and 99202)
  • Low (CPT codes 99213 and 99203)
  • Moderate (CPT codes 99214 and 99204)
  • High (CPT codes 99215 and 99205)

While these four coding levels have remained consistent, the MDM table of risk has been revised to focus on activities that affect the management of a patient’s condition. MDM is defined by three core elements: 

Note that only two of the three MDM elements are required for the overall MDM level. The physician may select the code based on the highest component documented (time or medical decision-making).

Medical Decision-Making Component

The number and complexity of problems addressed during the encounter

The amount and complexity of data to be reviewed and analyzed

The risk of complications, morbidity, and/or mortality or patient management decisions made during the visit

Stay Ahead of E/M Coding Changes With Our Other Services

HIS has decades of experience providing practices with medical billing and coding services. From coding education and consulting to professional training, we can help you stay aware of the latest coding updates in the healthcare field.

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Split (Or Shared) E/M VisitsExpert Medical Billing and Coding Services at HIS

A split (or shared) visit is any visit in which E/M services are performed in a facility setting by a physician and a non-physician practitioner (NPP) in the same group. When two or more individuals jointly meet with the patient, the time should only be counted once — increments of time should never be double-counted. CMS states that services should be reported by the clinician who performs a substantive portion of the visit. By 2023, the substantive portion will be defined as more than half of the total time spent. Split (or shared) visits can be reported for new and established patients, initial and subsequent visits, as well as prolonged services.The ultimate goal for the 2022 E/M changes is to reduce the administrative burden and increase the number of time physicians can spend with their patients. At Healthcare Information Services (HIS), we are committed to helping medical practices across the United States stay on top of the latest coding and documentation changes. Through consistent training and education, we’ll ensure your team has the knowledge and skills to code accurately and efficiently. Contact us if you have any questions about our services or schedule a consultation today!

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