AMA Releases 2023 E&M Updates

Emphasis is on relieving the administrative burden placed on physicians.

In 2021, American Medical Association (AMA) CPT® Editorial Panel approved and published new documentation guidelines for Office and Other Outpatient Evaluation and Management (E&M) CPT® codes (99202-99215, deleting 99201) and their code descriptors and documentation standards that directly addressed the continuing problem of administrative burden for physicians in nearly every specialty, from across the country.

After these revisions were implemented, in 2021, the challenge facing physicians was the need  for them to manage two sets of documentation rules; one for the office, and one for hospital E&M visits.

We have good news, on this front as the CPT® Editorial Panel has now approved, for 2023, additional revisions (PDF) to the rest of the E&M code section. These revisions seek to provide continuity across all the E&M sections allowing for the revisions implemented in the E&M office visit section in 2021 to extend to all other E&M sections.

The Centers for Medicare & Medicaid Services (CMS) also has a stake in this update and published its version of the new updates in the recently published newsroom article (July 7).

Evaluation and Management (E&M) Visits

As reported by AMA:

As part of the ongoing updates to E&M visits and related coding guidelines that are intended to reduce administrative burden, the AMA CPT® Editorial Panel approved revised coding and updated guidelines for Other E&M visits, effective January 1, 2023. Similar to the approach we finalized in the CY 2021 PFS final rule for office/outpatient E&M visit coding and documentation, we are proposing to adopt most of these changes in coding and documentation for Other E&M visits (which include hospital inpatient, hospital observation, emergency department, nursing facility, home or residence services, and cognitive impairment assessment) effective January 1, 2023. This revised coding and documentation framework would include CPT code definition changes (revisions to the Other E&M code descriptors), including: 

• New descriptor times (where relevant).  
• Revised interpretive guidelines for levels of medical decision making.  
• Choice of medical decision making or time to select code level (except for a few families like emergency department visits and cognitive impairment assessment, which are not timed services).  
• Eliminated use of history and exam to determine code level (instead there would be a requirement for a medically appropriate history and exam).

We are proposing to maintain the current billing policies that apply to the E&Ms while we consider potential revisions that might be necessary in future rulemaking. We are also proposing to create Medicare-specific coding for payment of Other E&M prolonged services, similar to what CMS adopted in CY 2021 for payment of Office/Outpatient prolonged services.

The following is also a summary of some “key” revisions to the E&M code descriptors and guidelines for 2023.

Expect deletion of observation CPT® codes (99217-99220, 99224-99226) and merged into the existing hospital care CPT codes (99221-99223, 99221-99233, 99238-99239), with updated code  descriptors.

Consultations will get a facelift, with the deletion of some confusing guidelines, including the definition of “transfer of care” and in keeping with the level one deletions as MDM duplication, expect to see the deletion of lowest level office (99241) and inpatient (99251) consultation codes to align with four levels of MDM.

Nursing facility services, along with home and residence services will also see revisions inline with similar documentation rules as the 2021 office visit revisions.

Programming Note: Listen to Terry Fletcher’s live reporting on the new AMA CPT® changes today during Talk Ten Tuesdays at 10 Eastern.

References and Resources:

https://www.cms.gov/newsroom/fact-sheets/calendar-year-cy-2023-medicare-physician-fee-schedule-proposed-rule

https://www.ama-assn.org/system/files/2023-e-m-descriptors-guidelines.pdf