Accreditation & Regulatory Journal
January 2023

CIHQ-ARS Article

Evaluation And Management Round 2… Documentation, Coding, And Compliance. Will You Be Ready For The Changes?

Big Changes for All Other E/M Codes In 2023… Will You Be Ready and Compliant?
January 1st, 2021, the Evaluation and Management (E/M) Office or Other Outpatient CPT® codes changed considerably. The reason why is because the American Medical Association (AMA) listened to providers’ concerns about the administrative burden associated with the documentation requirements for the E/M CPT codes and made changes. The 2021 changes allowed the E/M services to be reported based on either medical decision making (MDM) or Time for these office visits.
The AMA also announced that the remaining sections of E/M services will have major revisions effective on January 1st, 2023. This would include sections such as: inpatient and observation, emergency department, consultations, and other areas.
In February 2021, the AMA CPT Editorial Summary outlined proposed changes to the other sections of E/M for implementation January 1st, 2023. These changes build on the revisions to Office/Outpatient E/M codes in 2021 that emphasized medical decision making and sought to reduce documentation burden. The full details have not been released yet, but a summary of proposed changes are listed here:
  • Deletion of Observation Codes 99217 through 99226
    • This includes: Observation discharge (99217), initial observation (99218-99220), and subsequent observation (99224-99226).
  • Revision of Codes and Guidelines
    • For initial hospital care (99221-99223), subsequent hospital care (99231-99233), admission and discharge on the same date of service (99234-99236), and hospital discharge (99238-99239).
  • Deletion of Consultation Codes
    • 99241 (Office consultation for a new or established patient, which requires these 3 key components: A problem focused history; A problem focused examination; and Straightforward medical decision making.) and 99251 (Inpatient consultation for a new or established patient, which requires these 3 key components: A problem focused history; A problem focused examination; and Straightforward medical decision making.)
  • Revisions of the Guidelines for Emergency Department
    • ED visits are not defined as new or established patients. When selecting a level of service in 2023, use medical decision making. Time is not a factor in ED visits.
    • Prolonged Services
  • Deletion of annual nursing facility assessment code 99318.
    • Revision of all other codes and guidelines
  • Domiciliary, Rest Home (e.g., Boarding Home), or Custodial Care Services
    • The Domiciliary, Rest Home (e.g., Boarding Home), or Custodial Care Services subsection of CPT® 2023 is deleted, along with new patient codes 99324-99328 and established patient codes 99334-99337.
    • Domiciliary, Rest Home (e.g., Assisted Living Facility), or Home Care Plan Oversight Services guidelines are revised, and supervision codes 99339-99340 are deleted.
    • Home visit code 99343 is also deleted. And the remaining home visit codes (99341-99345, 99347-99350) are revised, as are the guidelines for using those codes.
The following chart provides a quick overview of where those changes will hit.
Service setting/type New codes Deleted codes Revised codes
Hospital Inpatient, including Observation 0 7 11
Consults 0 2 8
Emergency Department 0 0 5
Nursing facility 0 1 7
Domiciliary, Rest Home (e.g., boarding home), or Custodial care 0 9 0
Domiciliary, Rest Home (e.g., assisted living facility), or Home Care Plan Oversight 0 2 0
Home 0 1 8
Prolonged 2 4 2
What Providers Need To Know About The January 1st, 2023 Changes to be Compliant:
Changes implemented in 2021 included providing physicians and other qualified health care professionals the flexibility to select a level of service based on the complexity of medical decision making or total time on the day of service including work completed when the patient wasn’t present. E/M codes that have levels of services include a medically appropriate history and/or physical examination, when performed. The nature and extent of the history and/or physical examination are determined by the treating physician or other qualified health care professional reporting the service. The care team may collect information, and the patient or caregiver may supply information directly (e.g., by electronic health record [EHR] portal or questionnaire) that is reviewed by the reporting physician or other qualified health care professional. The extent of history and physical examination is not an element in selection of the level of these E/M service codes.
2023 Highlights Include:
Level of E/M services will be based on the following:
  • The level of the MDM as defined for each service
  • The total time for the E/M service performed on the date of the encounter. Time spent by the practitioner includes face-to-face and non-face-to-face time
  • History and exam no longer used to select the level of code
How to Prepare and be Compliant...
Training Needs to Occur...
Knowing not only the 2023 changes but knowing what’s on the horizon for the “Other” E/M is as equally important to be prepared.
BDA is offering a complimentary Preliminary Analysis that will focus on your current documentation and coding. This analysis will contain potential growth opportunities related to your organization. To learn more please visit or contact BDA at to schedule your complimentary analysis!