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E/M Documentation Training Recap: Quick Answers to Frequently Asked Coding Questions

In February, CAP hosted a webinar on Evaluation and Management coding, titled 2023 E/M Billing, Coding, and Documentation Rules Impacting Your Practice, presented by healthcare coding and billing expert, Terry Fletcher.

During the one-hour presentation, Ms. Fletcher covered a number of E/M rules and 2023 updates, including time-based versus Medical Decision Making (MDM) guidelines, Public Health Emergency (PHE) guidelines and changes, and hospital coding. To view the full program or obtain the slides referenced in the answers below, please click here:…

On-Demand Webinar: Key Strategies for Ensuring a Profitable Independent Practice
During this one-hour program, practice management expert Debra Phairas discusses how various business models and operational enhancements can increase revenue to help your practice remain successful in today’s competitive marketplace.

The following represents the top 10 questions submitted by the live webinar attendees, answered by Ms. Fletcher.


Q.   Anthem Blue Cross California is not accepting the 99222/99223 code for consultants, unless the claim is the first claim received. The guideline states it's to be used by one physician. Can you advise on this issue?

A.   Many payers, including Anthem, said they had a glitch in their system that was corrected in January 2023, and they will be sending payments, so do not rebill.


Q.   When do I use G-codes for prolonged time and when do I use 99415-type codes?

A.   G-codes are specific to Medicare when the highest code (level 5 in the office) or highest code in the hospital is exceeded by more than 15 minutes. See slides 52 and 53 of the presentation.


Q.   Is NO change of medication also considered prescription management? If I say, “Medication list was reviewed. At present, medication A is tolerated well and discussed with patient that patient should continue with the current medication at same dose”?

A.   Yes, but it is a best practice to also include the specific dosages and the status of the condition. See slides 7 and 8 of the presentation.


Q.   Can I use CPT code 99214 with POS 22?

A.   Yes, if you are asked to see a patient in the hospital observation setting or outpatient setting and they are established to you or your practice.


Q.   I thought another level of care that qualified as moderate was two or more stable chronic illnesses (that would normally be low-level complexity but if you have 2+ then it's moderate). Is that still true in 2023?

A.   It only qualifies for one element of the MDM for problems addressed. And, yes, that starts as moderate. But if there are no or low data points, and the only management is to RTC in 3-6 months, you are still at a level 3 visit or low level.


Q.   Can you skip billing for ordering lab work until the results come back and THEN document discussion of results?

A.   No. This question gets asked a lot and the AMA is clear that you bill in order. You can only bill for review of result if it's an external physician who originally ordered or someone in the group ordered that is in a different specialty, i.e., multi-specialty group.


Q.   If billing for a service as code 99215 and the session extends beyond the time limit, how do you bill the additional time?

A.   If the time for a level 5 has exceeded the maximum time listed in CPT by 15 additional minutes, then you can add 99417 for commercial insurance and G2212 for Medicare. These are getting audited. See slide 52 of the presentation.


Q.   Can you include EHR documentation time in the overall time?

A.   Yes, but there is also an expectation that the majority of the EHR documentation time will be done as the provider sees the patient. Also, that time documenting must be on the same date as the face-to face-encounter. Any charting the day before or after is not counted towards total time. See slide 14 in the presentation.


Q.   If a patient is non-compliant with healthcare and keeps going to the hospital ER, can we bill 99221-99223?

A.   These codes are only for inpatient or observation initial admissions. If you are seeing the patient in consultation from a repeat ER and asked to consult, you must use the 99233-99231 codes or 99215-99212 codes depending on the status of the patient.


Q.   Can we still use E/M codes with place of service 10 for telehealth?

A.   You can if you want to, but Medicare will reimburse the facility rate which is 20% below the Medicare Fee Schedule. Until the end of 2023, if you use the POS 11 or where the patient would have been had they come into the office in person, you have payment parity. Once you start using POS 10 you will take the reduction.


CAP members who were unable to attend the live webinar and would like to watch the recorded version in its entirety may access it here:…  

Andie Tena is CAP’s Director of Practice Management Services. Questions or comments related to this column should be directed to