E&M timeframe for new patient vs. established patient

At one coding conference I heard someone state that if it has been x years since you saw a patient and they come back to your office, that visit can be billed as a new patient instead of an established patient. What I can't remember is whether that time frame was 2 years or 3 years. Help?

new patient

three years

http://www.codapedia.com/-article_55_.cfm

new patient

That would be 3