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10 Ways to Prepare for E&M Changes in 2021

Wednesday, January 29, 2020 9:00 AM

Billing, Coding & Compliance, Practice Operations

Written by: Elizabeth Cifers, Kirk Mack, Laurie Brown, Patricia Kennedy

From left, BSM Senior Consultants L. Elizabeth Cifers, Kirk Mack, Laurie Brown, and Patricia Kennedy

The beginning of a new year brings with it a plethora of coding and compliance changes. As practices implement 2020 updates, they may be looking forward to some breathing room before they must prepare for the next set of annual changes. However, the processes providers currently use to document Evaluation and Management (E&M) services for Medicare will need to be altered drastically — and soon — in response to office E&M code changes, effective Jan. 1, 2021. Practices must begin preparing now to ensure a seamless transition.

Among the upcoming E&M changes is the elimination of code 99201, Office or other outpatient visit for evaluation and management of a new patient. In addition, physicians will be able to choose how they document the level of service by selecting an E&M code based on (1) the total time documented in a patient’s medical record or (2) the current medical decision-making (MDM) structure (the requirements of which will be made more clear with CMS revisions).

These changes are part of the Patient Over Paperwork Initiative, which aims to reduce the documentation burden on covered health care providers. While Medicare is the only payer currently discussing these changes, the conversation follows recent efforts by the Centers for Medicare and Medicaid Services (CMS) to make health care more efficient and patient-centric.

Implement Change Effectively

The impact these 2021 E&M changes will have means practices need to begin evaluating current workflows, thinking, planning, and strategizing now. You may recall how workflow and processes changed when moving from ICD-9 to ICD-10 in 2015; practices will need to prepare and implement scheduled 2021 E&M updates in much the same way. Below are suggestions to help get you started.

  1. Designate a project lead. The variety of tasks requiring attention will necessitate a strong team leader to ensure nothing is missed. Designate a point person to coordinate all the elements associated with documentation changes.

  2. Allow for preparation time. As with any systemic change, staff and providers need time to identify the processes that will be impacted. Allow ample time for this and implementation of the newly devised workflow plan.

  3. Educate on coding and documentation changes. Ensuring that providers, scribes, technicians, and billers are educated on the required coding and documentation changes is imperative for successful implementation. This knowledge will allow them to review, update, and finalize paper charts — whether used as primary documentation or as backup to electronic health records (EHRs) — before the start of 2021.

  4. Communicate with your EHR vendor. Many practices have protocols set up in their EHR systems to facilitate E&M code suggestions; the upcoming changes in coding and documentation criteria will require re-thinking this process. It is important that you engage your EHR vendor early this year to begin communicating about software modifications.

  5. Update protocols and workflow documents. Most practices have written protocols and workflow documents to ensure staff perform tasks consistently. Once the team has reviewed and revised these documents, memorialize the changes by the start of the new year.

  6. Revisit policies and procedures. After protocols and workflows are changed to align with the new processes, it is important to review practice policies and procedures to ensure the documents accurately capture internal operations. In addition, review your compliance plan as it relates to policies and procedures for consistency purposes.

  7. Become educated on commercial payer requirements. While most commercial insurance payers follow CMS and American Medical Association (AMA) guidelines, it is important to check with your payers to know if their coding and documentation requirements are unchanged.

  8. Consider the financial impact. Changes to relative value units (RVUs) and fee schedules will have a financial impact on the practice. Perform a financial analysis as part of your due diligence and anticipate their impact.

  9. Discuss documentation changes with medical malpractice liability insurers. Contact your medical malpractice insurer to understand its expectations for the new documentation requirements, receive guidance on new best practices, and learn if there will be a change in the liability limits.

  10. Stay compliant with federal and state regulations. Ensuring compliance with all federal and state regulations is imperative. The False Claims Act, along with other federal and state fraud and abuse laws, remain in effect. Practices should understand the new documentation requirements and continue to document and code appropriately.

Give Yourself Plenty of Time

As you’ve read, there are many steps practices need to take to prepare for scheduled 2021 E&M changes. Give yourself plenty of time to work out the resulting workflow and process updates by starting early this year. Doing so should yield positive results and set your practice up for successful implementation when E&M documentation and coding changes go into effect in 2021.

NEED HELP? Rose & Associates, a division of BSM Consulting, can help you transition to the new E&M codes. Call 1-800-720-9667.

2 Comments

  • Christopher Coad MD said Reply

    Are there any changes to the eye specific codes 92004, 92014, 92002 and 92012?

    • BSMAdmin said Reply

      Hi Dr. Coad,

      Thank you for contacting us with your question. We are not aware of any changes, and the information from CMS and AMA has not indicated eye codes will be affected by the change to the E/M documentation requirements.

      Please let me know if you have any other questions.

      Thank you,
      L. Elizabeth Cifers

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