Coding Guideline Changes

2021 E/M Coding Guideline Changes

October 6, 2020

Are You Prepared for the 2021 E/M Coding Guideline Changes?

The Evaluation and Management (E/M) changes take effect on January 1st, 2021 for New and Established Office/Outpatient codes. It is important to note that these changes are NOT going to impact other E/M categories.

In essence, clinicians can focus on tasks that affect the management of a patient’s problem or condition – thus enabling the documentation to reflect what has changed since last visit or on pertinent items that have not changed, rather than re-documenting this information.

Codes Impacted:

  • The new coding guideline changes apply only to codes 99202 – 99215
  • New Patient code 99201 will be eliminated
  • Code selection will be based on Medical Decision-Making or total time spent on the date of the encounter by a clinician

History & Physical Exam Documentation:

  • Office and other outpatient E/M services include “a medically appropriate history and/or exam, when performed”
  • The code selection will not depend on the level of history or exam performed. However, it must still be documented to help support the medical necessity of the service provided.
  • Information collected by the “non-clinical care team” and the patient (i.e. via portal or questionnaire) is still acceptable. However, the clinician must document evidence of their review.

Medical Decision-Making & Medical Necessity:

  • Number & Complexity of Problems Addressed: Problems addressed or those increasing the risk of complications and/or morbidity or mortality in management of the patient
  • Amount and/or Complexity of Data to be Reviewed and Analyzed: Changes reflect specific combinations of different data categories
  • Risk of Complications and/or Morbidity or Mortality of Patient Management: Now one column and uses only the treatment options from the “old” Table of Risk


  • Counseling and coordination of care is no longer a requirement for  time-based level selection
  • Time now includes the billing provider’s total time, including non-face-to-face time
  • Time cannot include time spent by ancillary staff and/or separately billable procedures and services. Only the time the clinician(s) spent will be counted.

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