Just when you think you are finally getting the hang of the E/M coding changes that became effective on January 1, 2023, the AMA announced further revisions on March 1, 2023 which are retroactive to January 1, 2023. This article discusses the changes in the March 3, 2023 CPT Errata & Technical Corrections and also includes a preview of upcoming 2024 changes.

Tip: In case you missed it, on February 1, 2023, the Prolonged Services table for “Total Duration of Office or Other Outpatient Consultation Services (use with 99245) was updated to correct the printed time of “80-99 minutes” to be “85-99 minutes.”

Independent Interpretation E/M Definition 

The definition for “Independent interpretation” was revised as of January 1, 2023 and again on March 1, 2023 as noted below (additional text is underlined and removed information is in strikeout text). The highlighted and underlined text was part of the March 1, 2023 revisions.

Independent interpretation: The interpretation of a test for which there is a CPT code, and an interpretation or report is customary. This does not apply when the physician or other qualified health care professional who reports the E/M service is reporting the service or has previously reported the test service for the patient. A form of interpretation should be documented but need not conform to the usual standards of a complete report for the test. A test that is ordered and independently interpreted may count both as a test ordered and interpreted.

Appropriate Source E/M Definition 

The 2023 CPT codebook does not show any changes for this definition, but the following clarification (underlined text) was added in the Errata:

Appropriate source: For the purpose of the discussion of management data element (see Table 1, Levels of Medical Decision Making), an appropriate source includes professionals who are not health care professionals but may be involved in the management of the patient (eg, lawyer, parole officer, case manager, teacher). It does not include discussion with family or informal caregivers. For the purpose of documents reviewed, documents from an appropriate source may be counted.

Office or Other Outpatient Guidelines

The introductory guidelines to the Office or Other Outpatient E/M category removed the reference to when a patient is considered an outpatient as noted in the strikeout text below:

The following codes are used to report evaluation and management services provided in the office or in an outpatient or other ambulatory facility. A patient is considered an outpatient until inpatient admission to a health care facility occurs.

E/M Revisions Coming in 2024

In February 2023, the CPT Editorial Panel met and approved further E/M Revisions which are currently scheduled to take place in January 2024. Be watching for any further announcements. They stated that the following are scheduled:

  • Revision of Office or Other Outpatient codes 99202-99205, 99212-99215
  • Revision of Nursing Facility Care codes 99306 and 99308
  • Revision of the E/M Introductory guidelines as follows:
    • Addition of guidelines for Split or Shared Visits and Multiple Evaluation and Management Services on the Same Date
    • Revision of Initial Hospital Inpatient or Observation Care/New or Established Patient guidelines
    • Revision of Hospital Inpatient or Observation Care Services (Including Admission and Discharge Services) guidelines
    • Prolonged Service With or Without Direct Patient Contact on the Date of an Evaluation and Management Service guidelines

Note: In 2025, a new E/M subsection for Telemedicine Services is scheduled to be implemented. It will include 17 new codes and guidelines which will replace codes 99441, 99442, and 99443.