What’s Next? Proposed E/M Rule Changes for 2023

Nancy Clark:The American Medical Association has been very candid about future changes to all of the remaining places of service for evaluation and management. While we don't have a great amount of detail yet, in March, the CPT Editorial Summary of Panel Actions was released. Generally, they indicate that we can expect to see the next round of E&M changes in 2023, which are anticipated to include the places of service that are remaining. Hospital inpatient, including observation, consultation codes, emergency department, nursing and rest homes, and home services are all expected to change.

There's also indication that prolonged services will be further revised. The guidance indicates that some codes are expected to be deleted in their entirety while others will undergo description revisions. Both headlines and guidelines within CPT have been identified for change. While there is limited detail from the AMA, we can also expect CMS, the Centers for Medicare and Medicaid Services to have a say in how this proceeds. There's still little doubt in the health care community that we can expect changes to take place.
LM:Well, providers will have two years to prepare, so that's good news. But what should they do now?
NC:Working with the new changes for office and outpatient codes will get providers' mindsets into the appropriate frame. Understanding and documenting both medical decision-making and time when appropriate will begin to enforce the needed concept changes in providers' documentation. In addition, periodic coding and documentation reviews will provide updated insight on compliance. We recommend reviews at six month intervals to identify if providers are still on the right track. And probably most important, both provider and staff education is critical to ensure understanding. A small proactive session now can minimize risk of revenue loss due to payer audits as well as ensure compliance moving forward.
LM:So will it be easier to implement inpatient codes since the practices have already gone through outpatient changes?
NC:In many ways, yes, if the provider has used the two years in between to improve his or her documentation. Keep in mind though that at this time, there are three levels of inpatient codes while there are four to five levels of outpatient codes. Therefore, the concept of leveling these E&M visits is somewhat different.
LM:So what do you think will be the key issues then, Nancy?
NC:I would recommend keeping apprised of the changes and preparing prior to implementation in order to avoid any incorrect coding issues and the related time and revenue loss. I would also recommend being aware of any discrepancies between carriers, such as with prolonged codes. And most importantly, simply ensure that all documentation supports the code levels billed. While some carriers' attentions may have been temporarily diverted over the past year, there's no doubt that payer audits will resume and impact practices revenue. In today's health care climate, it is more important than ever to ensure you are retaining what you earn.
LM:Thank you for your insights, Nancy. That's the last of our podcast series on E&M coding changes. Be sure to check out our other health care podcast series.

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