CMS Releases Final Rule for 2023

Now that CMS has implemented its Final Rule for 2023, ALL visits will match the general framework of the office/outpatient E&M visits, including inpatient and observation visits, emergency department (ED) visits, nursing facility visits, domiciliary or rest home visits, and home visits.

  • Medically Appropriate History
  • Medically Appropriate Physical Exam

If these are documented, all visits will be based on either Medical Decision Making (MDM) or Time (with the exception of Emergency Department Visits.

MDM is still determined by first assessing the level of each element:

  • Complexity
  • Data
  • Risk

MDM is the level of the remaining element after dropping the highest and lowest leveled elements.   Specialty specific MDM Guides are available by contacting E&M Consulting.

Observation Codes (99218-99220 & 99224-99226) have been deleted.  You should use 99221-99223 & 99231-99233 (formerly inpatient codes).  Place of Service (POS) is still required (inpatient: 21, observation: 22).

Domiciliary or rest home visits (99324-99328, & 99334-99337), and one CPT code in the Home Services family (CPT code 99343) have been deleted.  You should use 99341-99350 (formerly home visit codes).  Place of Service (POS) is still required (home: 12, assisted living: 13, or group home: 14).

Rules for billing visits based on time have also changed to match the general framework of the office/outpatient E&M visits.  All time spent before, during, and after the visit on the date of service (hospital), all time spent 1 day before visit + date of visit + 3 days after the visit (nursing facility), and 3 days before visit + date of visit + 7 days after the visit (home).  The total time includes face-to-face and non-face-to-face time.  Time Guides are available by contacting E&M Consulting.

Leave your comment