Everyone is still getting to know the new guidelines for E/M codes 99202-99215, including the members of the CPT Assistant editorial team. As a recent correction shows, the ongoing learning process means practices should be prepared for sudden reversals on fresh guidance.
The original question appeared in the July 2021 edition of CPT Assistant and concerned everyone’s favorite topic: How to count tests toward medical decision-making (MDM). Specifically, can two physicians or qualified health care professionals (QHP) of the same specialty or medical group count the review of test results at different visits? (Assuming the test was not reported by the practice, of course.)
The answer to that scenario was "no," but the answer went on state that it may be appropriate for the two providers to count the test if one provider counted the order of the test at one visit and a second provider counted the review of the test results at a later visit.
“If the tests were only ordered (ie, not reviewed and interpreted) by the first physician or QHP during the previous encounter, it may have been appropriate for the second physician to receive credit for reviewing the tests during a subsequent encounter, even if they are from the same specialty and/or the same medical group,” the original answer to the question stated.
However, an erratum issued in the August 2021 issue of CPT Assistant overturned the guidance for the test order/test review split.
“If the tests were only ordered (ie, not reviewed and interpreted) by the first physician or other QHP during the previous encounter, it would not have been appropriate for the second physician to receive credit for reviewing the tests during a subsequent encounter because they are from the same specialty and medical group and ordered tests are considered reviewed.” (Emphasis added.)
Practices that incorporated the July guidance into their training and compliance plans should update their documents and make sure staff are aware of the change. And stay tuned for more refinements on the new E/M guidance.