Evaluation & Management Coding Changes in the 2021 Physician Fee Schedule Final Rule

Office/Outpatient E/M Payments & Guidelines
Beginning Jan. 1, 2021, the CMS will align the E/M visit coding and documentation policies with changes created by the AMA CPT Editorial Panel for office/outpatient E/M visits. This includes finalizing key revisions to provider times used for rate-setting for the office/outpatient E/M visit code set.

Under the new CPT outline of office/outpatient E/M services adopted by the CMS, providers will no longer have to use history and examination to select the level of an E/M visit. Rather, documentation guidelines for office services levels 2 through 5 will be based on either the redefined medical decision-making or total time spent by the provider. Recording the history and exam are still necessary components and should be included for the medical record when reasonable, necessary and clinically appropriate, but will not be used to determine the visit level code submitted for reimbursement. These changes to the E/M codes were designed to make documenting office visits simpler and more flexible by reducing documentation burden through a more streamlined reporting process for E/M levels, improve payment accuracy and better reflect the current practice of medicine.

The CMS also finalized separate payments for two new add-on HCPCS codes, G2211 (which replaces temporary HCPCS add-on code GPC1X) and G2212 (replaces the temporary CPT code 99XXX). G2211 was created to capture the work for office/outpatient E/M visits not accounted for in the valuation of the primary office/outpatient E/M visit code. G2212 is for prolonged services and can only be reported when time is used to select the visit level.

Summary of Codes and Work RVUs Finalized for CY 2021

The ACR has applauded the CMS for making these long-awaited updates to cognitive care reimbursement in its CY 2021 Medicare PFS final rule. These much-needed Medicare rate increases for E/M services provided by rheumatologists and other cognitive care specialties to Medicare beneficiaries are crucial to the future of the rheumatology specialty and the continued delivery of high-quality rheumatology care.  To ensure these long overdue E/M rate increases do not lead to rate cuts to other medical specialties including physical and occupational therapists, the ACR is also leading advocacy efforts in support of H.R. 8505, legislation that would provide for a one-year waiver of budget neutrality adjustments. In November, the ACR led more than 60 groups in sending a letter to Congressional leaders urging them to support the bipartisan legislation, which was introduced by Reps. Michael Burgess (R-TX) and Bobby Rush (D-IL).