E/M changes are coming.  Lucky for us, we have almost a whole year to figure them out! They are set to take effect on January 1, 2021.  The American Medical Association (AMA) has published the changes, as well as numerous tools to assist us. Let’s take a closer look at our Top 10 List of Things you need to know about these new changes:

      1. The changes only pertain to Office or Other Outpatient E/M Codes (99202-99215). This means you will use the new guidelines when coding for office or other outpatient services, NOT for any other types of services.  If you code both inpatient and outpatient, this could get confusing!
      2. History and exam elements are determined by the provider and are not an element in E/M level selection. Wahoo!  No more counting HPI elements!
      3. The E/M level can be supported on total time OR level of medical decision making (MDM). The guidelines state this is an either time or MDM situation, so documentation need not support both in any manner.  If using MDM, there is not a required minimum amount of time.
      4. Code 99201 has been deleted. To report, see code 99202.  Currently, 99201 and 99202 both require straightforward medical decision making, and since history and examination are no longer an element in E/M selection (see #2), code 99201 is not needed.
      5. Time requirements have been redefined for each level of service to include exact increments of time required to move to the next code level. This removes the ‘midpoint’ vs. ‘threshold’ debate.
      6. “Time” is specified as total time on the date of the encounter, including both face-to-face and non-face-to-face time spent by the provider. This eliminates the requirement that over 50% of the total time (spent face-to-face) must be spent in counseling or coordination of care.
      7. Prolonged services will only be reported with codes 99205, 99215 in 15-minute increments beyond the defined service time. It is only reported when the service is selected using time and allows for face-to-face and non-face-to-face time spent by the provider on the date of the encounter.  This code has not been released yet.
      8. The three elements of MDM have been defined as:
        • Number and Complexity of Problems Addressed at the Encounter;
        • Amount and/or Complexity of Data to be Reviewed and Analyzed; and
        • Risk of Complications and/or Morbidity or Mortality of Patient Management.
          Two of the three elements must meet the level of MDM and there are four levels (straightforward, low, moderate, high).  This is all familiar but not quite exactly what we are used to, especially the data piece, which bring us to #9.
      9.  Data has been divided into three categories:
        • Tests, documents, order, or independent historians – each unique test, order, or document is counted to meet a threshold;
        • independent interpretation of tests not reported separately; and
        • discussion of management or test interpretation with external provider/appropriate source.

        This creates and standardizes a way for us to account for quantity of data ordered/reviewed.

        10. The AMA has created a table for coding E/M based on MDM and has also published the guidelines, including definitions. The definitions aim to clear up ambiguous terms; it is imperative to understand these definitions and the table to select an E/M level.

        Be sure to check out our webinar to learn more about these changes, and check out the AMA Code and Guideline Changes document:  https://www.ama-assn.org/system/files/2019-06/cpt-office-prolonged-svs-code-changes.pdf.

        Does your department need education regarding the 2021 E/M updates? Contact us today!




Shea is a consultant for The Haugen Consulting Group with 11 years of health care industry experience. Shea has experience working on the professional fee side of coding, auditing, education and compliance serving coders and physicians.

She earned a bachelor’s degree in health information management and a master’s degree in health services administration from the University of Kansas. Shea is a Registered Health Information Administrator (RHIA), Certified Professional Coder (CPC), Certified Professional Medical Auditor (CPMA) and a Project Management Professional (PMP).

Shea, her husband, and their daughters, call the wide-open spaces of central Kansas home.


  1. physicianbiller

    Hey Shea, I love this post, Thanks for your honesty and this was very informative it helped me. This blog was essential in our understanding of physician medical billing situations. We maintain a website concerning this aspect in which we provide a physician revenue cycle management (RCM) and make strategies to improve them.

  2. eric slowik

    I thought the wbinar was helpful

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