Medicare Guidance Changes for E/M Services

October 11th, 2023 - Wyn Staheli

2023 brought quite a few changes to Evaluation and management (E/M) services. The significant revisions as noted in the CPT codebook were welcome changes to bring other E/M services more in line with the changes that took place with Office or Other Outpatient Services a few years ago. As part of CMS’ Medicare Learning Network, the “Evaluation and Management Services Guide” publication was finally updated as of August 2023 to include the changes that took place in 2023.

If you take a look at the new publication (see references below), you’ll see quite a bit of red throughout. That red text indicates something that has been revised since its previous publication.

Although it’s nice to see that this helpful publication by CMS has been updated throughout to incorporate these changes, it should be noted that there are some other changes that will be in the 2024 CPT codebook which will likely require a change to the following table which appears in the current version of CMS’ “Evaluation and Management Services Guide”:

Table 2. Codes for Billing Prolonged Office or Outpatient E/M Visits
Codes	Total Time Required for Reporting*
99205	60-74 minutes
99205 x 1 and G2212 x 1	89-103 minutes
99205 x 1 and G2212 x 2	104-118 minutes
99215	40-54 minutes
99215 x 1 and G2212 x 1	69-83 minutes
99215 x 1 and G2212 x 2	84-98 minutes
99215 x 1 and G2212 x 3 or more for each additional 15 minutes	99 or more
*Total time is all of the reportable time, including prolonged time, you spend with the patient on the date of service of the visit.

Medicare had issues with the time that a prolonged service would be reported with code 99417 and thus created their own prolonged service code (G2212). In case you missed it, on February 9, 2023, CMS released an update to Chapter 12, section 30.6.15.3 for “Prolonged Other E/M Visits” which had an implementation date of May 9, 2023. The times for reporting prolonged services with “Hospital Inpatient and/or Observation” (99221, 99233, 99236) were revised as shown in the following table:

	OLD Time Range		NEW Time Range
99223 Initial	75-104 105-119 120-134 135+	99223 only 99223 + G0316 x1 99223 + G0316 x2 For each addt’l 15 min, report an addt’l unit of G0316	75-89 90-104 105-119 120+	99223 only 99223 + G0316 x1 99223 + G0316 x2 For each addt’l 15 min, report an addt’l unit of G0316
99233 Subsequent	50-79 80-94 95-109 110+	99233 only 99233 + G0316 x1 99233 + G0316 x2 For each addt’l 15 min, report an addt’l unit of G0316	50-64 65-79 80-94 95+	99233 only 99233 + G0316 x1 99233 + G0316 x2 For each addt’l 15 min, report an addt’l unit of G0316
99236 Admit/Discharge	85-124 125-139 140-154 155+	99236 only 99236 + G0316 x 1 99236 + G0316 x 2 For each addt’l 15 min, report an addt’l unit of G0316	85-109 110-124 125-139 140+	99236 only 99236 + G0316 x 1 99236 + G0316 x 2 For each addt’l 15 min, report an addt’l unit of G0316

In light of these changes to time ranges, it should be noted that there are going to be additional changes in 2024 to the times for Office or Other Outpatient Visits (99202-99215). As such, it is very likely that there will also be changes made by CMS to accommodate these revisions. We will make more information available about the 2024 changes in an upcoming article once the 2024 Medicare Physician Fee Schedule Final Rule has been published.

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