AMA says these are proposed, not finalized.
The American Medical Association (AMA) Editorial Panel met in February to discuss proposed changes to the CPT® Code Book. The formal proposal published on March 5 was a reflection of the discussion, and it raised certain issues that stakeholders will now have an opportunity to weigh in on after review.
To be clear, as stated in the proposal, “codes are not assigned, nor exact wording finalized” – as this remains a work in progress.
What follows are several highlights of some of the proposed changes to keep an eye on, as the AMA panel has made it clear in the past year that more changes will come to the evaluation and management (E&M) side of the coding spectrum to better capture the most routine codes providers are using, while eliminating codes that do not have a high volume of reporting.
Inpatient and Observation Services
Codes 99217-99226 may be deleted, and language added to the initial and subsequent inpatient codes, 99221-99223 and 99231-99233, for observation hospital E&M services. This would be a revision to the latter, as the observation codes are reimbursed poorly for a patient who may be in the “observation hospital unit” for up to 48 hours – or longer. This could be for payment parity for hospital patients. This change looks to be more favorable to the physician than the facility coding piece, as a change in definition from observation to inpatient could affect reimbursement, from Outpatient Prospective Payment System (OPPS) capitated claims to per-diem hospital reimbursement. This would take effect Jan. 1, 2023.
Consultation Services, Inpatient and Outpatient
Codes 99251 and 99241 are proposed to be deleted by 2023, in keeping with the seldom-reported Level 1 services. We already saw this change for 2021 with the office and other outpatient visits, and the deletion of the Level 1 new patient office visit, 99201, so this change was expected.
Emergency Department Visits
Codes 99281-99285 look to be getting a language revision of the code descriptor, but the change was not clear in the proposal.
Home Health and Residence E&M Encounters
It appears that this section has many repetitive or similar codes in the portions that include home health, domiciliary care, rest home, and assisted living care. The proposal looks to streamline these services into a single tabbed section for home health services. This makes sense and should be approved for revision by Jan. 1, 2023.
Several new codes look as though they could be added into this section, along with a revision of the new 99417, to include non-face-to-face time on the same date – to enhance accuracy when added to the Level 5 Office or Other Outpatient Visits, 99205 or 99215. This update would take effect by January 2023, although I could see this being updated by 2022 based on necessity for a sooner clarification, because this new 2021 add-on code is already being reported. It is also proposed to delete the existing prolonged services codes 99354-99357, as they are not permitted with office visits in 2021.
More on procedural change proposals coming soon.