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AMA updates two data definitions, hints at changes in 2024 and beyond

You can assign two data points when a provider orders and interprets a test, and count documents from an appropriate source toward data review. The new guidance applies to medical decision-making (MDM) for all level-based E/M visits. It was issued in the March 1 version of the errata and technical corrections for the 2023 CPT manual and released March 3. The changes are retroactive to Jan. 1.
There are more E/M changes on the way in 2024 and 2025, according to the CPT Editorial summary of panel actions that the AMA published March 3. But for now, open your 2023 CPT manual to the section for amount and/or complexity of data to be reviewed and analyzed category and add the text in bold to the definitions for independent interpretation and appropriate source:
  1. Independent interpretation: The interpretation of a test for which there is a CPT code, and an interpretation or report is customary. This does not apply when the physician or other qualified health care professional who reports the E/M service is reporting or has previously reported the test. A form of interpretation should be documented but need not conform to the usual standards of a complete report for the test. A test that is ordered and independently interpreted may count both as a test ordered and interpreted.
  2. Appropriate source: For the purpose of the discussion of management data element (see Table 1, Levels of Medical Decision Making), an appropriate source includes professionals who are not health care professionals but may be involved in the management of the patient (eg, lawyer, parole officer, case manager, teacher). It does not include discussion with family or informal caregivers. For the purpose of documents reviewed, documents from an appropriate source may be counted.
A third change deletes the following sentence from the guidelines for office/other outpatient visits:
“A patient is considered an outpatient until inpatient admission to a health care facility occurs.”
Part B News subscribers can download the new worksheet for level-based E/M visits.
You’ll find glimpses of the future – for E/M coding at least – in the summary of panel actions from the CPT Editorial Panel & HCPAC Annual Meeting, Feb. 2-4.
The summary doesn’t contain details but it does alert you to code changes that will go into effect Jan. 1, 2024:
  • All office/other outpatient visits that have a time element (99202-99205 and 99212-99215).
  • Two nursing facility codes (99306 and 99308).
You’ll also see the following revisions to the guidelines for E/M services:
  • Split or shared visits and multiple evaluation and management services on the same date.
  • Initial hospital inpatient or observation care/new or established patient.
  • Hospital inpatient or observation care services, including admission and discharge.
  • Prolonged services with or without direct patient contact on the date of an E/M service.
The summary also previews a major revision to the telephone E/M code set, but you’ll have two years to prepare. Telephone codes 99441-99443 will be deleted and replaced by 17 new codes, effective Jan. 1, 2025. Expect new guidelines to go with the new codes.
Part B News will share more information about the next round of E/M updates when it is available.
Blog Tags: AMA, E/M services
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