More E/M changes on the horizon?

June 29, 2022 / By Courtney Crozier, RHIA, CCS

It feels like only yesterday that the health care industry was preparing for the new Evaluation and Management (E/M) 2021 guidelines, which brought about significant change. Just when we’re all getting comfortable with the updated guidelines, a new batch of E/M changes may be on the horizon for 2023.   

In February 2021, the AMA CPT® Editorial Panel released a summary of proposed changes to other sections of E/M with an effective date of January 2023: 

E/M service 

Proposed changes 

Inpatient and Observation Care Services 

Deletion of the following codes: 

  • Observation care discharge: 99217 
  • Initial observation care: 99218-99220 
  • Subsequent observation care: 99224-99226 

Revision of the following codes to include observation care services, and revision of subsection headings and guidelines:  

  • Initial hospital care: 99221-99223 
  • Subsequent hospital care: 99231-99233 
  • Observation or inpatient care: 99234-99236 
  • Hospital discharge management: 99238-99239 

Consultations 

Deletion of the following codes: 

  • Office or other outpatient consult (lowest level): 99241 
  • Inpatient consultation (lowest level): 99251 

Revision of the following codes including headings and guidelines: 

  • Office or other outpatient consult: 99242-99245 
  • Inpatient consultation: 99252-99255 

Emergency Department Services 

Revision of the following codes and guidelines: 

  • Emergency department: 99281-99285 

Nursing Facility Services 

Deletion of the following codes: 

  • Other nursing facility services: 99318 

Revision of the following codes and subsection guidelines: 

  • Initial nursing facility care: 99304-99306 
  • Subsequent nursing facility care: 99307-99310 

Home and Residence Services 

Deletion of the following codes: 

  • Domiciliary, rest home, or custodial care services new patient: 99324-99328 
  • Domiciliary, rest home, or custodial care services established patient: 99334-99337 
  • Domiciliary, rest home, or home care plan oversight: 99339-99340 
  • Home services new patient (moderate to high): 99343 

Revision of the following codes including headings and guidelines: 

  • Home services new patient: 99341-99345 
  • Home services established patient: 99347-99350 

Prolonged Services 

Deletion of the following codes: 

  • Prolonged service with direct patient contact: 99354-99357 

Revision of the following codes including headings and/or guidelines: 

  • Prolonged service with or without direct patient contact on the date of an office or other outpatient service: 99417 
  • Cognitive assessment and care plan services: 99483 


So what exactly do the above changes mean?  
 

Inpatient and observation:
The observation services codes may be deleted and language added to the initial and subsequent inpatient services codes to include those observation services. The shift from inpatient to outpatient care could  be a reason for the change.  

Consultation:
Very similar to what we saw in 2021 with the deletion of the lower level office and other outpatient services codes, the lower level consultation codes may be deleted with revisions to the headings and guidelines. 

Emergency department: 
It doesn’t seem that much is changing for the emergency department codes. Only language revisions of the code description and revisions in the guidelines were proposed.   

Nursing facility services: 
The annual nursing facility assessment code may be deleted. Only language revisions of the code description and revisions in the guidelines for initial and subsequent nursing care were proposed.   

Home and residence services: 
Much of this section seems to  overlap with services and locations: domiciliary, rest home, boarding home, assisted living, custodial care, home care plan, home services, etc. The proposed changes look to combine all residence locations under one section for home services.   

Prolonged services: 
Prolonged services codes with direct patient contact (face-to-face) in the outpatient, inpatient and observation setting may be deleted with a revision of the prolonged service with/without direct patient contact on the date of an office or other outpatient service code, 99417. 

As mentioned above, the changes listed are currently proposed changes and have not been finalized. As of June 3, 2022, the AMA’s CPT Editorial Panel has not released the final approved E/M changes for 2023.  

Another set of significant E/M changes may be on the horizon, so hopefully the AMA will provide additional details, guidelines, articles, etc. as we get closer to the fall of 2022. Keep an eye out for those upcoming changes! 

February 2021: CPT® Editorial Summary of Panel Actions (ama-assn.org) 

Courtney Crozier is a clinical development analyst 3M Health Information Systems.