03/17/2021

More Changes to 2021 E & M Outpatient Visit Guidelines Announced!

Now you can count CBCs as MDM Data even if you bill for them!

By, Jim Leach, MBS, CPMA, E & M Consulting, Inc.

For those of you who attended the MSHO February 16th webinar I presented on the new 2021 E&M Guidelines for office visits, you may be surprised that last Tuesday, March 9th, the AMA issued some clarifications to their own rules, I certainly was!  Although none of us like changes, they are actually advantageous to oncology.  Let me describe them for you.

Medical Decision Making (MDM) - Data:  Previously you were not allowed to count any tests that you performed and billed for in your office (eg. Blood work).  Now you can!!  The AMA clarified that any test that does not contain a work RVU, or a professional component, CAN be counted as data, even if you bill for the test!  Blood tests, such as CBCs have no work RVU or professional component and therefore you CAN count them as MDM Data when scoring your note.

All radiology tests HAVE a professional component.  This means that if your office bills for a radiology test and your physician bills for his/her interpretation (eg CT abdomen 74176-26) it cannot be counted as data.  If your office doesn’t bill for the radiology test, but the physician does their own interpretation of the test, it CAN be counted in Category 2 for MDM Data (Independent interpretation of a test performed by another physician/other qualified health care professional (not separately reported))

MDM Risk:  The AMA previously applied risk to diagnostic testing and management options only, and not the status of disease.  But what about when treatment for a cancer is completed and the patient is now under surveillance only?  Isn’t there a still a risk (eg. Risk of recurrence?).  The answer is YES!  This type of assessment of risk is up to the interpretation of the provider.  For example, if a colon cancer patient has no evidence of disease, it may be the opinion of the provider that the patient still has some kind of a risk for recurrence.  How much? Minimal, Low, Moderate, or High?  It is up to the provider.  If the patient is 5 years out and still no evidence of disease, the provider might call the risk minimal (level 2) or low (level 3).  This could result in a 99213 instead of 99212.  The risk could be even higher earlier on.

As you can see, these MDM changes will have a dramatic impact in oncology.  Of note, there were NO changes to choosing your level based on time.  If you have any questions related to any of the changes, I urge you to contact Michelle Weiss via email at billing@msho.org.

To view the March 9th Guidance by the AMA which includes the changes mentioned above, “technical corrections” and more;  CLICK HERE