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Important E&M Updates from National Government Services

National Government Services (NGS), our local Medicare carrier, has posted some changes to its previous publications surrounding three important areas of Evaluation & Management coding and documentation guidelines.

  • Consultative Services: In 2010, CMS stopped accepting consultation codes (9924X and 9925X). Since that time, consultations have been reported with new patient codes in the out-patient setting and initial care codes in the in-patient setting. NGS has now further defined that when a provider requests the consultative opinion of another provider, the consulting provider must perform the service independently, and cannot split/share the required elements of the consultative E&M service. This does not impact the out-patient services where shared/split visits do not exist. However, this does impact the in-patient services and specifically CPT® codes 99221-99223 when they are billed as representative of consultative services (not as the attending physician of record). If any portion of the documentation is authored by the non-physician practitioner, the service must be billed with the non-physician practitioner’s name and NPI.
  • Observation Services: When a patient is receiving out-patient observation services, only the attending physician of record (or another member of the same group in the same specialty) may use the observation codes (99218-99220 and 99224-99226). Services provided by providers of other specialties may use a corresponding out-patient code (9920X or 9921X).
  • Level of Examination: Effective July 1, 2017, NGS has re-defined the documentation requirements for the exam component of E&M Services. An expanded problem-focused exam will require the documentation of 2 to 5 organ systems or body areas, whereas a detailed exam will require the documentation of 6 to 7 organ systems or body areas.

We have included the links to the NGS website where these bulletins can be found.

Thank you,

Dr. Koch

Medical Director

Consultative and Observation Services: click here for bulletin >>

Examination Documentation: click here for bulletin >>