In November 2018, CMS issued its final rule for the Medicare Physician Fee Schedule. In a previous article, we had summarized the changes to E&M coding that CMS had proposed in its July 27, 2018 proposed rule. In this final rule, CMS delayed until 2021 any changes to reimbursement for E&M codes to allow for additional comments and further preparation to implement changes.

In commenting on the delay in the effective date, CMS Administrator Seema Verma stated, "We know that this is going to have a tremendous impact on many doctors in America, and we want to make sure we get this right." CMS noted the additional time will allow additional refinements to the intended changes.

CMS adopted certain changes that will be effective next year (2019), including:

In the changes to be effective in 2021, CMS changed its approach to bundling for E&M visits by excluding Level 5 visits, as well as Level 1 visits, from the bundled payment amount. CMS stated that it was making this change to better account for the needs of complex patients and the services being provided to those patients. As a result, in 2021, there are three payment levels for E&M visits for both new and established patients, as follows

  1. 99201 – Level 1 new patient office visit
  2. 99202 through 99204 – Levels 2 through 4 new patient office visit
  3. 99205 – Level 5 new patient office visit
  4. 99211– Level 1 established patient office visit
  5. 99212 through 99214 – Levels 2 through 4 established patient office visit
  6. 99215 – Level 5 established patient office visit

Additional changes relating to E&M coding incorporated into the final rule, to be effective in 2021, are:

The final rule can be found here.

Kimberly A. Lammers