Is your practice ready for 2021 E/M changes? Preparation tips

Oct. 26, 2020 / By Danielle Pavloski

We are only a few months away from the new Evaluation and Management (E/M) changes being implemented. The American Medical Association (AMA) officially released the new E/M guidelines and changes affecting the E/M office visit codes. These changes will go into effect on January 1, 2021. It is important for every practice to understand what these changes entail, how they will affect the practice and how to prepare for these changes.

As my fellow blogger Colleen Deighan discussed in her recent blog, in order to help you understand and prepare for the upcoming E/M changes, a team of 3M coding experts will blog about different components of the changes in detail over the coming weeks as we prepare for the effective date of January 1, 2021.

Why are E/M changes being implemented?

Historically, the E/M guidelines have not been updated since 1997. Currently, there are two sets of guidelines in place, the 1995 E/M guidelines and the 1997 E/M guidelines. The Centers for Medicare and Medicaid Services (CMS) revised the documentation guidelines in 1992, 1995 and the final update was in 1997. Think about this in light of all the changes that have occurred in health care in the last 25 years (e.g., electronic health records, electronic claim forms, performance measures, value-based care, etc).

The Centers for Medicare and Medicaid Services (CMS) received numerous comment letters from providers and organizations that perceived the current E/M office visit codes and guidelines as “outdated.” CMS released the Medicare E/M Initial 2019 proposal in 2018 which outlined the need to simplify code selection, remove unnecessary history and physical examination elements, and condense visit-payment amounts.

A workgroup was formed as a collaborative effort between the AMA and CMS that included stakeholders from both provider and payer organizations. The focus of the workgroup was to:

• Reduce administrative burden of documentation and coding for providers and decrease physician burnout by:
  • Removing scoring by history and examination code in tune with the way providers think.
• Decrease unnecessary documentation that is not needed for patient care in the medical record and give providers more time to focus on patient care by:
  • Eliminating history and examination scoring in order to promote higher-level activities of medical decision making.
• Ensure the E/M payment is resource-based by:
  • Using current medical decision making criteria (CMS and educational/audit tools to reduce likelihood of change in patterns).

As a result of the collaborative effort between the AMA and CMS, the following changes were adopted into the CPT code set and will be implemented on January 1, 2021:

• Extensive additions and revisions to the E/M guidelines
• Deletion of code 99201 and revision of codes 99202-99215
• Components for code selection (MDM or total time on the date of the encounter).

What does your practice need to do to prepare?

In order to better prepare for the upcoming changes, you should develop an action plan for your practice that we recommend include the following components:

• Education
  • First and most importantly, ensure your staff is well educated on the changes (guidelines, definitions and components of code selection). Our educational series can help your staff and providers better understand these changes in more detail, as well as get ready for these changes.

• Training
  • Provide training to your staff and providers. Make certain both staff and providers understand how to apply these changes and how to select the levels of E/M office visit codes based on the new guidelines.

• Compliance
  • Make certain you update your compliance plan and polices in accordance with CPT guidelines and CMS policy changes.

• Auditing
  • Conduct audits on documentation, coding and billing to identify any deficiencies and areas that need improvement with E/M documentation.

• Financial impact analysis
  • Since the RVUs will be changing, it is important to conduct a financial impact analysis in order to determine how these changes will impact the revenue for your practice.

• Technology
  • Update your EHR and any other systems with the new guidelines, code and RVU changes.

Focusing on the above components will better prepare your practice, providers and staff for the upcoming changes.

In our upcoming blog series, we will discuss the E/M changes in more detail and cover the new guideline definitions for the independent historian, acute illness or injury, stable chronic problem, and the impact of including social determinants of health in the E/M code level selection. Stay tuned for our E/M blog series to learn more about these important changes and how they will impact your practice.

Danielle Pavloski is a quality manager for the CodeComplete team at 3M Health Information Systems.

Learn more about the 2021 E/M changes.