Countdown to the E/M Coding Changes


The biggest changes in evaluation and management coding since 1997 will take effect Jan. 1, 2021. It is time to prepare for them now.

Fam Pract Manag. 2020 Sep-Oct;27(5):29-36.

Author disclosure: no relevant financial affiliations disclosed.

Editor's note: In its 2021 Medicare Physician Fee Schedule, CMS released new guidance regarding coding for prolonged E/M services. This article has been updated accordingly.

Say goodbye to counting exam bullet points and making sure you have correctly separated your history of present illness from your review of systems: Changes are coming that should streamline your coding and help you zip through your documentation faster.

The shift in required documentation for CPT codes 99202-99215 takes effect Jan. 1, 2021. Coding for office visits will be based solely on medical decision making (MDM) or total time, and the history and exam components will no longer be used.1 It's the biggest change in evaluation and management (E/M) office coding since 1997.

The reforms will apply only to regular office visits (levels 2–5 for new and established patients) — not other visit types (e.g., nursing home or hospital visits) — and should help simplify many aspects of coding. They will allow family physicians to produce shorter, more readable notes that will enhance patient care and save time. They will also lead to more accurate coding and allow us to be reimbursed more fairly for the work we do.

This article outlines what you need to know about the new rules, and it includes some templates to help you prepare your mind and your EHR.


  • The biggest changes in evaluation and management coding in more than two decades take effect Jan. 1, 2021. They will allow physicians to code office visits based only on total time or medical decision making.

  • The medical decision making coding method relies on three categories: problems (the severity of the conditions for which you're seeing the patient), data (what you had to review for the visit), and risk (the patient's morbidity or mortality odds).

  • You can start creating coding tables and templates now, so your EHR will be optimized for faster documentation once the new rules go into effect.


Total time will be measured as the time the physician or other qualified health professional spent on that patient on the day of the encounter. It will include time spent before, during, and after the visit, including time spent documenting the visit. Yes, that means after Jan. 1, “pajama time” (the time you spend finishing your charts after your kids are asleep) can be reimbursed. But get your charts done before midnight, because time spent the following day cannot be counted.

Hospital coding can already use time spent on the patients' unit/floor before and after the visit to determine the level of service, while office coding currently counts only face-to-face time. Allowing coding by total time will correct this double standard.

On the day of the patient encounter, total time will include time


Dr. Millette is a family physician practicing at Altru Family Medicine Center in Grand Forks, N.D. He has been teaching coding to physicians for more than 15 years.

Author disclosure: no relevant financial affiliations disclosed.


1. CPT evaluation and management (E/M) office or other outpatient (99202-99215) and prolonged services (99354, 99355, 99356, 99XXX) code and guideline changes. American Medical Association. 2019. Accessed Aug. 12, 2020.


For more information on the coding and documentation changes, including the AAFP's new E/M reference card, visit


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