2021 Medicare Physician Fee Schedule Final Rule Concludes Office/Outpatient E/M Code Updates

2021 Medicare Physician Fee Schedule Final Rule Concludes Office/Outpatient E/M Code Updates

The Centers for Medicare & Medicaid Services (CMS) released their Final Rule for the 2021 Medicare Physician Fee Schedule on December 1, 2020 (CMS, 2020).

All eyes have been on the Final Rule for a finalization on the much-anticipated office/outpatient Evaluation and Management code updates. Furthermore, per CMS, “in CY 2021, we will be largely aligning our E/M visit coding and documentation policies with changes laid out by the CPT Editorial Panel for office/outpatient E/M visits, beginning January 1, 2021” (2020).

However, most noticeable was the addition of a separate HCPCS code, G2212, describing prolonged services for the office/outpatient E/M visits. Therefore, this code is designed to be utilized in place of CPT code 99417 for prolonged services for Medicare payers.

These codes have two different time requirements, so coders and providers will both need to pay close attention to the documentation and payer per encounter.

Thus, 99417 per page 43 in the CPT book is as follows:

In addition, G2212 per the Final Rule is as follows:

Category 1 Codes

Another notable finalization in the Final Rule is the addition of telehealth services. “Services added to the Medicare telehealth list on a Category 1 basis are similar to services already on the telehealth list:

• Group Psychotherapy (CPT code 90853)
• Psychological and Neuropsychological Testing (CPT code 96121)
• Domiciliary, Rest Home, or Custodial Care services, Established patients (CPT codes 99334-99335)
• Home Visits, Established Patient (CPT codes 99347-99348)
• Cognitive Assessment and Care Planning Services (CPT code 99483)
• Visit Complexity Inherent to Certain Office/Outpatient Evaluation and Management (E/M) (HCPCS code G2211)
• Prolonged Services (HCPCS code G2212)” (CMS, 2020)

Category 3 Codes

“The following codes were added to the Medicare telehealth list on a Category 3 basis (through the calendar year of which the public health emergency ends):

• Domiciliary, Rest Home, or Custodial Care services, Established patients (CPT codes 99336-99337)
• Home Visits, Established Patient (CPT codes 99349-99350)
• Emergency Department Visits, Levels 1-5 (CPT codes 99281-99285)
• Nursing facilities discharge day management (CPT codes 99315-99316)
• Psychological and Neuropsychological Testing (CPT codes 96130-96133; CPT codes 96136-96139)
• Therapy Services, Physical and Occupational Therapy, All levels (CPT codes 97161-97168; CPT codes 97110, 97112, 97116, 97535, 97750, 97755, 97760, 97761, 92521-92524, 92507)
• Hospital discharge day management (CPT codes 99238-99239)
• Inpatient Neonatal and Pediatric Critical Care, Subsequent (CPT codes 99469, 99472, 99476)
• Continuing Neonatal Intensive Care Services (CPT codes 99478-99480)
• Critical Care Services (CPT codes 99291-99292)
• End-Stage Renal Disease Monthly Capitation Payment codes (CPT codes 90952, 90953, 90956, 90959, 90962)
• Subsequent Observation and Observation Discharge Day Management (CPT codes 99217; CPT codes 99224-99226)” (CMS, 2020)

CMS went on to clarify that “telehealth rules do not apply when the beneficiary and the practitioner are in the same location even if audio/video technology assists in furnishing a service” (CMS, 2020).

Furthermore, additional clarifications in the Final Rule include: remote physiologic monitoring policy changes, subsequent nursing facility frequency limitation, direct supervision by interactive telecommunications technology, and policies regarding professional scope of practice and related issues.

In addition, you can see the Final Rule or the fact sheet for more information.

You can also stay up-to-date on the 2021 IPPS Final Rule and the 2021 OPPS Final Rule with the YES Blog. Also, contact YES HIM Consulting’s team for their solutions on coding updates education, auditing services, denials remediation, and other HIM consulting needs.