Answering A Common 2021 E/M Question

Major revisions to the office/other outpatient evaluation and management CPT^® codes took effect January 1, 2021. One of the major changes is that providers can now choose the level of an office/other outpatient evaluation and management service based on medical decision making only or total time only.^1,2 When choosing that level based on medical decision making, one of the elements of decision making to consider is, “Amount and/or Complexity of Data to be Reviewed and Analyzed.”^1,2 One item that may account for “Amount and/or Complexity of Data to be Reviewed and Analyzed” is, “review of the result(s) of each unique test.”^1,2 As many providers perform their own in-office imaging, a common question associated with these new office/other outpatient evaluation and management guidelines is:

“Can I consider my review of an X-ray that I am billing for as a ‘review of the result(s) of each unique test?’”

Answer:  No

If a provider performs the technical component of an imaging service and the interpretation of the resulting image(s), and appropriately submits CPT^® coding reflecting the performance of both the technical and professional components of the imaging service, that provider cannot consider that professional component as “review of the result(s) of each unique test” in determining an evaluation and management level.^1,2 The reason is, the value associated with the review of this unique test would be already accounted for in the CPT coding reflecting the interpretation, and factoring this review into the selection of the evaluation and management code level would be “double dipping.” Alternatively, if a provider reviewed the results of a unique test whose interpretation was performed elsewhere, the work associated with the provider’s review should be considered in selecting the evaluation and management code level.   

References 

1. American Medical Association. 2021 CPT® Professional. Chicago:American Medical Association;2020.

2. American Medical Association. CPT® Evaluation and Management. E/M Office Revisions. Available at:  https://www.ama-assn.org/practice-management/cpt/cpt-evaluation-and-management?utm_source=Selligent&utm_medium=email&utm_term=%25m%25d%25y&utm_content=HS_CM_CPTNewsAlert_031021&utm_campaign=HS_CM_CPTNewsAlert_031021&utm_uid=12567066&utm_effort=&utm_h= . Published March 9, 2021. Accessed April 12, 2021.

Dr. Lehrman operates Lehrman Consulting, LLC, is a consultant to the APMA Health Policy and Practice Department, serves as an expert panelist on Codingline, and is a Certified Professional Coder. Follow him on Twitter @DrLehrman.

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