Clarifications issued for new E/M office visit rules

The CPT Editorial Panel has approved revisions that clarify some of the confusing parts of the new evaluation and management (E/M) office visit guidelines. The changes, which the panel called “technical corrections,” are effective retroactive to Jan. 1.

The panel made several revisions that pertain to medical decision making (MDM), including:

• Clarifying when to include a test that is considered, but not selected after shared decision making.
• Defining “analyzed” for the purposes of reporting tests in the data column.
• Clarifying what qualifies as a “unique” test.
• Clarifying the meaning of “discussion” between physicians and other qualified health care professionals (QHPs) and patients.
• Defining “major” surgery versus “minor” surgery.

The panel also clarified which activities are not counted when using total time for code level selection.

Among all of the clarifications, two stand out as particularly important:

1. You may count labs and tests performed as Category 1 MDM data if you’re not including any separate interpretation component. The revised language states, “Tests that do not require separate interpretation (e.g., tests that are results only) and are analyzed as part of MDM do not count as an independent interpretation, but may be counted as ordered or reviewed for selecting an MDM level.” Examples include complete blood count, urinalysis, rapid strep, and glucose, all of which have no interpretation component.

Others, such as pulmonary function tests, electrocardiograms, and x-rays have professional components included. If ordering physicians or QHPs perform the professional components of these tests and report those tests separately, they can not count those tests as data elements for determining MDM level. Likewise, time spent performing services that are separately payable can not be included for time-based coding.

2. The other revision of note is also in the data section of MDM. “Category 3: Discussion of management or test interpretation” is now more clearly described. “Discussion” is defined as a direct interactive exchange (not through intermediaries) that may be synchronous or asynchronous. It is expected that the communication occurs within a short time period surrounding the relevant visit (i.e., a day or two).

The CPT revisions have been posted to the American Medical Association (AMA) website’s E/M page. You can find the full set of modifications — and previous year’s CPT revisions — on the AMA’s CPT “Errata & technical corrections” page.

— Samuel Le Church, MD, AAFP CPT Advisor, and Kent Moore, Senior Strategist for Physician Payment

Posted on Mar 15, 2021 by Kent Moore