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This month we’re talking about 2021 E/M Coding and how you should get prepared. Our experts understand the confusion that can arise around coding, especially since it’s changing all the time. We’ve been hearing a lot about what’s coming in the new year. It’s just around the corner, and we want you to be clear about what it’s going to look like.

You might also like to check out September’s 3 Things to Know About RCM.

These are October’s three things to know.

In 2021, medical decision making (MDM) will become the primary factor for selecting the proper code from the 99202-99215 range (unless you decide to base the code on time).

The revised Level of MDM table is going to look different in 2021. Some of the revisions are a reflection of the way we talk about visits and complexity. Instead of “Number of Diagnoses or Management Options”, you’ll see “Number and Complexity of Problems Addressed at the Encounter.”

This means complexity will be evaluated in new ways. The final diagnosis does not in itself determine the complexity/risk. In fact, multiple problems of a lower severity may, in the aggregate, create a higher risk due to interaction.

This is good for providers because, when they accurately document their thought processes, treatment planning, and getting to the final diagnosis, they will get full credit for all that thinking. And documentation will make a difference.

You’ll see new guidance around analysis and review of data.

In 2021, providers will get some credit for analyzing and interpreting data.

This data will include records, tests, and/or other information that the provider must obtain, order, review, and analyze for the encounter, per the new CPT® 2021 E/M guidelines. This data also includes information obtained from multiple sources or interprofessional communications that are not separately reported, as well as the interpretation of tests that are not separately reported.

Data will be reported at three levels, Low, Moderate, and High MDM and must meet specific requirements based on a new table.

Steps to Fast-track Your 2021 MDM Implementation

There’s still time to get ready for the extensive changes to the office and outpatient E/M codes guidelines ahead. Do these things to move forward with confidence.

Prepare for New MDM Table and Time Chart

For 2021 office E/M services, you’ll base the level of service on time or medical decision making (MDM)—not both—just one or the other. Be sure everyone on your staff knows that MDM is defined by three things: number/complexity of problems addressed in the encounter; amount/complexity of data reviewed and analyzed; and the risk of complications/morbidity/mortality of patient management decisions associated with the patient’s problem, diagnostic procedure, and treatment.

Tip: You must meet at least three MDM levels.

Get Familiar with Updated Terminology

In the 2021 E/M overhaul, the AMA has attempted to clear up vague terminology. It introduced some new terms, like “independent historian” and clarified some ambiguous terms with solid definitions. Be sure practitioners, coders, and auditors learn the new language to ensure accuracy.


Give your staff the opportunity to practice with test cases. Take past or current encounters and run through them based on the new guidelines before they take effect.

Interested in more coding updates?

Check out Experity’s Coding Center and see how other coding updates will affect your urgent care.

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