To the Editor:
I enjoyed “An Update on the E/M Codes and Documentation Guidelines” [May 2003, page 14] by Kent Moore, but it induced a panic attack. I have read various versions of the vignettes proposed to help describe each level of service, and they seem capricious, arbitrary and very subjective. I don’t think I could ever use them to justify coding a higher level, as any auditor could have a different opinion that I would have no way to objectively dispute. Although the current guidelines are far from perfect, I have learned to use them to objectively support my coding. I hope they remain unchanged until I can retire out of this mess.
The AAFP shares your concerns. The Academy believes that, like you, family physicians have adapted to the current evaluation and management (E/M) codes and the associated documentation guidelines for E/M services. Also, like you, the Academy questions the proposed dependence on brief clinical examples to guide coding. Such examples may make choosing E/M codes more intuitive for physicians, but the Academy believes they will provide precious little defense in an audit situation. The AAFP also has doubts about the ability of clinical examples to ensure work equivalency across specialties under the resource-based relative value scale (RBRVS).
The Academy and other national specialty societies have communicated these concerns to the AMA CPT Editorial Panel and have urged the Panel, as a prerequisite to implementation, to get in writing from the Centers for Medicare & Medicaid Services (CMS) a commitment to 1) accept the new code descriptors for Medicare and Medicaid and not create its own coding system for E/M services and 2) officially indicate what, if any, set of documentation guidelines it will use based on these new code descriptors. In the meantime, if the Panel continues in its present direction, the Academy does plan to participate in developing the clinical examples and would also plan to assist in reviewing draft proposals for the new code descriptors so that the results are as useful to family physicians as possible.