Robin's Guide to 2021 E/M Changes

Dr. Kathleen Myers
Oct 23, 2020
4 min

What your practice should know about 2021 E/M calculation.

In early 2019, CMS made the landmark decision to overhaul its current E&M coding practices and documentation guidelines to reduce the administrative burden on physicians and more accurately calculate visit complexity. The revised changes are set to go into effect starting January 1, 2021. At Robin, we use algorithms to stay constantly in-sync with payer rules. Our algorithms use these payer rules to produce justified accurate coding, streamlined into a physician’s documentation from a smart device placed in the clinic room, saving physicians hours a day on administrative documentation. We have a few tips to ensure your 2021 documentation supports the latest new criteria.

Removal of History and Physical Exam sections
Billing is now focused on the level of medical decision-making (MDM) or total time spent on a patient. With this change, comprehensive history and physical exam documentation are no longer necessary for E&M code selection. However, Robin recommends including medically relevant history and physical exam in the clinical documentation, though it can be brief or captured by ancillary medical staff and reviewed by the billing provider.

A comprehensive history and physical exam documentation are no longer necessary for E&M code selection, but MDM requirements are undergoing changes. Here’s how you can adapt.

Billing based solely on Total Time or MDM
Time-based billing will now represent the total time spent assessing and managing a patient on the encounter date. Total time no longer needs to be dominated by coordination and counseling, and it will now incorporate both face-to-face and non-face-to-face time spent by the physician for the encounter. Here are some activities (if performed by the physician) that can count towards total time spent:

  • Preparing to see the patient (e.g., review of tests)
  • Obtaining and/or reviewing the separately obtained history
  • Counseling and educating the patient/family/caregiver
  • Ordering medications, tests, or procedures
  • Referring and communicating with other health care professionals (when not separately reported)

MDM-based billing will remain largely the same from a clinician standpoint, though the underlying code calculation will differ. MDM will continue to be determined by the number and complexity of diagnosis & management, data review, and risk elements. Minor updates have been made to the subcomponents of each of these elements, which are detailed below.

Updates to MDM Calculation
Not only have there been minor updates to the specific MDM criteria elements, but the calculation of the entire section has undergone a significant update as well. These changes have been implemented in Robin’s platform to emphasize better specific criteria that directly impact patient care and management. The bulk of changes have been made to the data review section of the MDM.

Here are three main points to help maximize your documentation in 2021:

  • Diagnosis and management will now mostly be dependent on the complexity of the problem(s) assessed. At Robin, we recommend dictating any relevant chronic comorbidities and status of the condition into our Robin Assistant™ device to help boost your MDM.
  • Data review will now take into account the total number of unique tests ordered and reviewed. However, to maximize your MDM, you will need to either perform an independent review of the diagnostic test(s) (not just a review of the report) or discuss the patient’s case with an external provider. Physicians that use Robin can dictate their A&P directly to the Robin Assistant in the room or the Robin App, and we will automatically capture and calculate your MDM.
  • Risk remains relatively unchanged and will still be reliant on the treatment plan items ordered or performed during the visit. We recommend continuing to clearly dictate the patient’s assessment and plan into the Robin Assistant for our Robin providers.
At Robin, we use algorithms to constantly stay in-sync with payer rules. We produce accurate codes, that are streamlined into physician’s documentation from a smart device placed in the clinic room.

New Prolonged Care code 99417
This new code can be used to denote increments of at least 15 minutes after the highest level of care has been exceeded for an outpatient or office visit. Each additional 15 minutes spent with the patient can be reported as another unit of 99417. Any time less than each 15-minute increment cannot be reported. This code will be used in place of the prolonged care codes 99354 and 99355 when in an outpatient or office visit setting.

Removal of 99201 E&M code
E&M code 99201 will no longer be a billable code for 2021. New patient E&M codes will default to 99202 as the minimum code. Please note that E&M code 99211 for established patients is still a viable code.

We hope this was valuable information as you shift your practice workflows for 2021 E&M changes. Follow us for more important updates in payer rules, healthcare technology, and beyond.

About Robin
Robin places its HIPAA-compliant device, The Robin Assistant™, in-clinic rooms to capture administrative requirements from the natural doctor-patient conversation ambiently. Using machine learning algorithms and natural language processing, Robin generates fully billable documentation with justified medical codes that are accurate and consistent with care, driving enhanced reimbursement to support any audit.

The platform uniquely blends cutting-edge software with quality assurance by trained healthcare staff and integrates directly with each physician’s electronic records. Physicians who use Robin in their clinics save precious time, see more patients, and are reimbursed more accurately for the care they provide. Read more at robin.co.

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