Cited by 5Medical Coding and Health InformationHealthcare Policy and ManagementMedical Research and Practices

E/M coding in 2021: the times (and more) are a-changin'

Open access
Flamm, Alexandra·2021·Cutis

Abstract

Major revisions for commonly reported office and outpatient evaluation and management (E/M) codes were implemented on January 1, 2021, by the American Medical Association and Centers for Medicare and Medicaid Services. The goal of these changes was to simplify and streamline these service codes, with time and medical decision-making (MDM) now being the sole determinants of the overall E/M level. We present an overview of the new guidelines, requirements, and code descriptors to aid in accurate documentation and billing. Additional resources are provided if further billing and coding questions arise.

AI snapshot

Written from the paper’s full text.

TL;DR

This article reviews the 2021 revisions to outpatient evaluation and management (E/M) coding from the AMA and CMS, explaining that visit level can now be based on total physician time or medical decision-making (MDM) rather than history and physical examination. It offers practical definitions and tables for dermatology documentation and billing.

Key findings

  • Effective January 1, 2021, office/outpatient E/M codes changed: 99201 was deleted, and 99211 lost its time component and is coded by MDM. Time ranges include new-patient 99202 at 15–29 minutes through 99205 at 60–74 minutes, and established-patient 99212 at 10–19 minutes through 99215 at 40–54 minutes.
  • Time can be used for any encounter and counts total physician time on the date of the encounter, including pre- or post-visit record review, care coordination, ordering tests, and documentation; clinical staff time is excluded. Shared time with a nurse practitioner or physician assistant cannot be counted twice—one example totals 35 minutes rather than 40.
  • MDM has three categories: number and complexity of problems addressed, amount/complexity of data reviewed or analyzed, and risk of complications/morbidity/mortality. At least two of the three categories must be met or exceeded for a given E/M level.
  • Risk is stratified as minimal, low, moderate, or high; examples include over-the-counter drug management as low, prescription drug management as moderate, and drug therapy requiring intensive toxicity monitoring as high. Problem-complexity examples range from suture removal and insect bites to flaring psoriasis, a melanoma-uncertainty differential, and toxic epidermal necrolysis.

Methods

  • Narrative educational review, not an empirical study; no sample, data collection, or statistical analysis is described.
  • Synthesizes AMA/CMS 2021 E/M guidelines and presents tables covering visit times, problem complexity, external data sources, and risk stratification, with dermatology-oriented examples.
  • Main analysis is descriptive: it explains how to select an E/M level using time or MDM and how to document accordingly.

Limitations

  • The paper states that clinical judgment is needed because some dermatologic conditions may fit more than one complexity level or may not be captured well by any level, and documentation should support the chosen level.
  • It advises consulting AMA or American Academy of Dermatology resources when definitions are unclear; no formal limitations section is provided.
  • Evident from the text: the article is a brief overview without original data or validation, and several tables appear only partially in the available text, so some definitions and examples may be incomplete.

Model-written summary. Check it against the paper before relying on it.

Integrity signals

Registry

Crossref · 10.12788/cutis.0270

Cites

Statistics

Nothing to recompute.

Claims the paper makes

0 of 30 cited sources checked · 0 supported · 0 flagged

  • Interpretationreasoning

    When a nurse practitioner or physician assistant assists and the physician reports the service, time spent together cannot be counted twice.

    “If you work with a nurse practitioner or physician assistant (PA) who assists you and you are the one reporting the service, you cannot double-dip.”
    Quote in the paperSubstantial claim
  • Interpretationreasoning

    The 2021 updates represent a notable change from the previous documentation requirements for this family of codes.

    “These updates represent a notable change from the previous documentation requirements for this oft used family of codes.”
    Quote in the paperSubstantial claim
    • Rests on an assumption: Prior to the 2021 revisions, a physician generally could only code for an E/M level by time for a face-to-face encounter dominated by counseling and/or care coordination.
  • Premisecitation

    Clinical staff time is not included in total time for E/M coding.

    “With the new updates, any encounter can be coded by total time spent by the physician with the patient 1 ; however, clinical staff time is not included.”
    Quote in the paperSubstantial claim0 of 1 sources checked
    • cites [1] 1. American Medical Association. CPT ® Evaluation and management (E/M) office or other outpatient (99202-99215) and prolonged services (99354, 99355, 99356, 99417) code and guideline changes. Accessed May 14, 2021. https://www.ama-assn.org/system/files/2019-06 /cpt-office-prolonged-svs-code-changes.pdf

      Not checked in the free run.

  • Premisecitation

    Major revisions for commonly reported office and outpatient E/M codes were implemented on January 1, 2021, by the American Medical Association and Centers for Medicare and Medicaid Services.

    “Major revisions for commonly reported office and outpatient evaluation and management (E/M) codes were implemented on January 1, 2021, by the American Medical Association and Centers for Medicare and Medicaid Services.”
    Quote in the paperSubstantial claim0 of 1 sources checked
    • cites [1] 1. American Medical Association. CPT ® Evaluation and management (E/M) office or other outpatient (99202-99215) and prolonged services (99354, 99355, 99356, 99417) code and guideline changes. Accessed May 14, 2021. https://www.ama-assn.org/system/files/2019-06 /cpt-office-prolonged-svs-code-changes.pdf

      Not checked in the free run.

  • Premisecitation

    The inclusion of non-face-to-face time applies only when these activities are done on the date of the encounter.

    “Importantly, this applies only when these activities are done on the date of the encounter.”
    Quote in the paperSubstantial claim0 of 1 sources checked
    • cites [1] 1. American Medical Association. CPT ® Evaluation and management (E/M) office or other outpatient (99202-99215) and prolonged services (99354, 99355, 99356, 99417) code and guideline changes. Accessed May 14, 2021. https://www.ama-assn.org/system/files/2019-06 /cpt-office-prolonged-svs-code-changes.pdf

      Not checked in the free run.

  • Classified as probably not a substantial claim. 18
  • May combine two claims. 4
  • The quote only partly states this claim. 1
  • Probably not a substantial claim: may not pass S3 (load-bearing).

    Premisecitation

    Risk is defined as the probability and/or consequences of an event and is based on the usual behavior and thought processes of a physician in the same specialty.

    “Risk is defined as the probability and/or consequences of an event and is based on the usual behavior and thought processes of a physician in the same specialty.”
    Quote in the paperNot a substantial claim0 of 1 sources checked
    • cites [1] 1. American Medical Association. CPT ® Evaluation and management (E/M) office or other outpatient (99202-99215) and prolonged services (99354, 99355, 99356, 99417) code and guideline changes. Accessed May 14, 2021. https://www.ama-assn.org/system/files/2019-06 /cpt-office-prolonged-svs-code-changes.pdf

      Not checked in the free run.

  • Classified as probably not a substantial claim.

    Premisecitation

    For purposes of MDM, risk is stratified into minimal, low, moderate, and high.

    “For the purposes of MDM, risk is stratified into minimal, low, moderate, and high.”
    Quote in the paperSubstantial claim0 of 1 sources checked
    • cites [1] 1. American Medical Association. CPT ® Evaluation and management (E/M) office or other outpatient (99202-99215) and prolonged services (99354, 99355, 99356, 99417) code and guideline changes. Accessed May 14, 2021. https://www.ama-assn.org/system/files/2019-06 /cpt-office-prolonged-svs-code-changes.pdf

      Not checked in the free run.

  • Probably not a substantial claim: may not pass S3 (load-bearing).

    Premisecitation

    For treatment and diagnostic options, risk includes both the options selected and those considered but not selected.

    “Importantly, for treatment and diagnostic options, these include both the options selected and those considered but not selected.”
    Quote in the paperNot a substantial claim0 of 1 sources checked
    • cites [1] 1. American Medical Association. CPT ® Evaluation and management (E/M) office or other outpatient (99202-99215) and prolonged services (99354, 99355, 99356, 99417) code and guideline changes. Accessed May 14, 2021. https://www.ama-assn.org/system/files/2019-06 /cpt-office-prolonged-svs-code-changes.pdf

      Not checked in the free run.

  • May combine two claims.

    Premisecitation

    History and physical examination documentation must be medically appropriate but are no longer used to determine overall E/M level.

    “History and physical examination documentation must be medically appropriate but are no longer used to determine overall E/M level; time and MDM are the sole options that can be used.”
    Quote in the paperSubstantial claim0 of 1 sources checked
    • cites [1] 1. American Medical Association. CPT ® Evaluation and management (E/M) office or other outpatient (99202-99215) and prolonged services (99354, 99355, 99356, 99417) code and guideline changes. Accessed May 14, 2021. https://www.ama-assn.org/system/files/2019-06 /cpt-office-prolonged-svs-code-changes.pdf

      Not checked in the free run.

  • Probably not a substantial claim: may not pass S3 (load-bearing).

    Premisecitation

    Risk of complications and/or morbidity or mortality of patient management relates to both the patient's diagnosis and treatment(s).

    “In this category, risk relates to both the patient's diagnosis and treatment(s).”
    Quote in the paperNot a substantial claim0 of 1 sources checked
    • cites [1] 1. American Medical Association. CPT ® Evaluation and management (E/M) office or other outpatient (99202-99215) and prolonged services (99354, 99355, 99356, 99417) code and guideline changes. Accessed May 14, 2021. https://www.ama-assn.org/system/files/2019-06 /cpt-office-prolonged-svs-code-changes.pdf

      Not checked in the free run.

  • Classified as probably not a substantial claim.

    Premisecitation

    For established patient E/M code 99213, total visit time is 20-29 minutes.

    “| 99213 | 20-29 min |”
    Quote in the paperSubstantial claim0 of 1 sources checked
    • cites [1] 1. American Medical Association. CPT ® Evaluation and management (E/M) office or other outpatient (99202-99215) and prolonged services (99354, 99355, 99356, 99417) code and guideline changes. Accessed May 14, 2021. https://www.ama-assn.org/system/files/2019-06 /cpt-office-prolonged-svs-code-changes.pdf

      Not checked in the free run.

  • Classified as probably not a substantial claim.

    Premisecitation

    Per the 2021 guidelines, MDM is comprised of 3 categories: number and complexity of problems addressed at the encounter, amount and/or complexity of data to be reviewed or analyzed, and risk of complications and/or morbidity or mortality of patient management.

    “Per the 2021 guidelines, MDM is comprised of 3 categories: (1) number and complexity of problems addressed at the encounter, (2) amount and/or complexity of data to be reviewed or analyzed, and (3) risk of complications and/or morbidity or mortality of patient management.”
    Quote in the paperSubstantial claim0 of 1 sources checked
    • cites [1] 1. American Medical Association. CPT ® Evaluation and management (E/M) office or other outpatient (99202-99215) and prolonged services (99354, 99355, 99356, 99417) code and guideline changes. Accessed May 14, 2021. https://www.ama-assn.org/system/files/2019-06 /cpt-office-prolonged-svs-code-changes.pdf

      Not checked in the free run.

  • Probably not a substantial claim: may not pass S3 (load-bearing).

    Premisecitation

    For new patient E/M code 99205, total visit time is 60-74 minutes.

    “| 99205 | 60-74 min |”
    Quote in the paperNot a substantial claim0 of 1 sources checked
    • cites [1] 1. American Medical Association. CPT ® Evaluation and management (E/M) office or other outpatient (99202-99215) and prolonged services (99354, 99355, 99356, 99417) code and guideline changes. Accessed May 14, 2021. https://www.ama-assn.org/system/files/2019-06 /cpt-office-prolonged-svs-code-changes.pdf

      Not checked in the free run.

  • Classified as probably not a substantial claim.

    Premisecitation

    For new patient E/M code 99202, total visit time is 15-29 minutes.

    “| 99202 | 15-29 min |”
    Quote in the paperSubstantial claim0 of 1 sources checked
    • cites [1] 1. American Medical Association. CPT ® Evaluation and management (E/M) office or other outpatient (99202-99215) and prolonged services (99354, 99355, 99356, 99417) code and guideline changes. Accessed May 14, 2021. https://www.ama-assn.org/system/files/2019-06 /cpt-office-prolonged-svs-code-changes.pdf

      Not checked in the free run.

  • Classified as probably not a substantial claim.

    Premisecitation

    E/M coding can be determined via the level of medical decision-making.

    “Evaluation and management coding also can be determined via the level of medical decision-making (MDM).”
    Quote in the paperSubstantial claim0 of 1 sources checked
    • cites [1] 1. American Medical Association. CPT ® Evaluation and management (E/M) office or other outpatient (99202-99215) and prolonged services (99354, 99355, 99356, 99417) code and guideline changes. Accessed May 14, 2021. https://www.ama-assn.org/system/files/2019-06 /cpt-office-prolonged-svs-code-changes.pdf

      Not checked in the free run.

  • May combine two claims.

    Premisecitation

    The 2021 E/M revisions were intended to streamline definitions, promote consistency, and decrease administrative burden.

    “which were the culmination of multiple years of revision and surveying via the American Medical Association (AMA) Relative Value Scale Update Committee and Current Procedural Terminology (RUC-CPT) process to streamline definitions and promote consistency as well as to decrease the administrative burden for all specialties within the house of medicine.1”
    Quote in the paperNot a substantial claim0 of 1 sources checked
    • cites [1] 1. American Medical Association. CPT ® Evaluation and management (E/M) office or other outpatient (99202-99215) and prolonged services (99354, 99355, 99356, 99417) code and guideline changes. Accessed May 14, 2021. https://www.ama-assn.org/system/files/2019-06 /cpt-office-prolonged-svs-code-changes.pdf

      Not checked in the free run.

  • Classified as probably not a substantial claim.

    Premisecitation

    If a problem is referred to another provider without evaluation or consideration of treatment, it is not considered a problem addressed and cannot count toward the first MDM category.

    “If the problem is referred to another provider without evaluation or consideration of treatment, it is not considered to be a problem addressed and cannot count toward this first category.”
    Quote in the paperSubstantial claim0 of 1 sources checked
    • cites [1] 1. American Medical Association. CPT ® Evaluation and management (E/M) office or other outpatient (99202-99215) and prolonged services (99354, 99355, 99356, 99417) code and guideline changes. Accessed May 14, 2021. https://www.ama-assn.org/system/files/2019-06 /cpt-office-prolonged-svs-code-changes.pdf

      Not checked in the free run.

  • Probably not a substantial claim: may not pass S3 (load-bearing).

    Premisecitation

    For new patient E/M code 99203, total visit time is 30-44 minutes.

    “| 99203 | 30-44 min |”
    Quote in the paperNot a substantial claim0 of 1 sources checked
    • cites [1] 1. American Medical Association. CPT ® Evaluation and management (E/M) office or other outpatient (99202-99215) and prolonged services (99354, 99355, 99356, 99417) code and guideline changes. Accessed May 14, 2021. https://www.ama-assn.org/system/files/2019-06 /cpt-office-prolonged-svs-code-changes.pdf

      Not checked in the free run.

  • The quote only partly states this claim.

    Premisecitation

    For new patient E/M code 99201, the code was deleted as of January 1, 2021.

    “| 99201 | Deleted |”
    Quote in the paperSubstantial claim0 of 1 sources checked
    • cites [1] 1. American Medical Association. CPT ® Evaluation and management (E/M) office or other outpatient (99202-99215) and prolonged services (99354, 99355, 99356, 99417) code and guideline changes. Accessed May 14, 2021. https://www.ama-assn.org/system/files/2019-06 /cpt-office-prolonged-svs-code-changes.pdf

      Not checked in the free run.

  • Classified as probably not a substantial claim. May combine two claims.

    Premisecitation

    Time includes reviewing notes or data before or after the examination, care coordination, ordering laboratory tests, and providing documentation related to the encounter.

    “This can include reviewing notes or data before or after the examination, care coordination, ordering laboratory tests, and providing any documentation related to the encounter.”
    Quote in the paperSubstantial claim0 of 1 sources checked
    • cites [1] 1. American Medical Association. CPT ® Evaluation and management (E/M) office or other outpatient (99202-99215) and prolonged services (99354, 99355, 99356, 99417) code and guideline changes. Accessed May 14, 2021. https://www.ama-assn.org/system/files/2019-06 /cpt-office-prolonged-svs-code-changes.pdf

      Not checked in the free run.

  • Probably not a substantial claim: may not pass S3 (load-bearing).

    Premisecitation

    For established patient E/M code 99214, total visit time is 30-39 minutes.

    “| 99214 | 30-39 min |”
    Quote in the paperNot a substantial claim0 of 1 sources checked
    • cites [1] 1. American Medical Association. CPT ® Evaluation and management (E/M) office or other outpatient (99202-99215) and prolonged services (99354, 99355, 99356, 99417) code and guideline changes. Accessed May 14, 2021. https://www.ama-assn.org/system/files/2019-06 /cpt-office-prolonged-svs-code-changes.pdf

      Not checked in the free run.

  • Classified as probably not a substantial claim.

    Premisecitation

    For established patient E/M code 99212, total visit time is 10-19 minutes.

    “| 99212E | 10-19 min |”
    Quote in the paperSubstantial claim0 of 1 sources checked
    • cites [1] 1. American Medical Association. CPT ® Evaluation and management (E/M) office or other outpatient (99202-99215) and prolonged services (99354, 99355, 99356, 99417) code and guideline changes. Accessed May 14, 2021. https://www.ama-assn.org/system/files/2019-06 /cpt-office-prolonged-svs-code-changes.pdf

      Not checked in the free run.

  • Classified as probably not a substantial claim.

    Premisecitation

    For established patient E/M code 99215, total visit time is 40-54 minutes.

    “| 99215 | 40-54 min |”
    Quote in the paperSubstantial claim0 of 1 sources checked
    • cites [1] 1. American Medical Association. CPT ® Evaluation and management (E/M) office or other outpatient (99202-99215) and prolonged services (99354, 99355, 99356, 99417) code and guideline changes. Accessed May 14, 2021. https://www.ama-assn.org/system/files/2019-06 /cpt-office-prolonged-svs-code-changes.pdf

      Not checked in the free run.

  • Probably not a substantial claim: may not pass S3 (load-bearing). May combine two claims.

    Premisecitation

    The amount and/or complexity of data to be reviewed and analyzed category encompasses external notes reviewed, unique laboratory tests or imaging ordered or reviewed, the need for an independent historian or discussion with external health care providers or appropriate sources, or independent interpretation of tests.

    “This category encompasses any external notes reviewed, unique laboratory tests or imaging ordered or reviewed, the need for an independent historian or discussion with external health care providers or appropriate sources, or independent interpretation of tests.”
    Quote in the paperNot a substantial claim0 of 1 sources checked
    • cites [1] 1. American Medical Association. CPT ® Evaluation and management (E/M) office or other outpatient (99202-99215) and prolonged services (99354, 99355, 99356, 99417) code and guideline changes. Accessed May 14, 2021. https://www.ama-assn.org/system/files/2019-06 /cpt-office-prolonged-svs-code-changes.pdf

      Not checked in the free run.

  • Probably not a substantial claim: may not pass S3 (load-bearing).

    Premisecitation

    For new patient E/M code 99204, total visit time is 45-59 minutes.

    “| 99204 | 45-59 min |”
    Quote in the paperNot a substantial claim0 of 1 sources checked
    • cites [1] 1. American Medical Association. CPT ® Evaluation and management (E/M) office or other outpatient (99202-99215) and prolonged services (99354, 99355, 99356, 99417) code and guideline changes. Accessed May 14, 2021. https://www.ama-assn.org/system/files/2019-06 /cpt-office-prolonged-svs-code-changes.pdf

      Not checked in the free run.

  • Classified as probably not a substantial claim.

    Premisecitation

    Per AMA guidelines, a problem addressed includes a disease, condition, illness, injury, symptom, sign, finding, complaint, or other matter addressed at the encounter that is evaluated or treated at the encounter by the physician.

    “Per AMA guidelines, this includes a disease, condition, illness, injury, symptom, sign, finding, complaint, or other matter addressed at the encounter that is evaluated or treated at the encounter by the physician.”
    Quote in the paperSubstantial claim0 of 1 sources checked
    • cites [1] 1. American Medical Association. CPT ® Evaluation and management (E/M) office or other outpatient (99202-99215) and prolonged services (99354, 99355, 99356, 99417) code and guideline changes. Accessed May 14, 2021. https://www.ama-assn.org/system/files/2019-06 /cpt-office-prolonged-svs-code-changes.pdf

      Not checked in the free run.

21 of 21
  • The paper relies on this without support.

    Prior to the 2021 revisions, a physician generally could only code for an E/M level by time for a face-to-face encounter dominated by counseling and/or care coordination.

    “Prior to the 2021 revisions, a physician generally could only code for an E/M level by time for a face-to-face encounter dominated by counseling and/or care coordination.”
  • The paper relies on this without support.

    Social determinants of health play a part in the risk category of MDM.

    “Social determinants of health also play a part in this category”
  • The paper relies on this without support.

    Social determinants of health can be indicated by the specific corresponding ICD-10 code and may need to be included in billing according to specific institutional or carrier guidelines if they are a factor in the level of MDM.

    “Social determinants of health can be indicated by the specific corresponding International Statistical Classification of Diseases, Tenth Revision code and may need to be included in your billing according to specific institutional or carrier guidelines if they are a factor in your level of MDM.”
  • The paper relies on this without support.

    Some entities and disease states in dermatology may fit the requirements of more than 1 level of complexity depending on the clinical situation.

    “Keep in mind that some entities and disease states in dermatology may fit the requirements of more than 1 level of complexity depending on the clinical situation”
  • The paper relies on this without support.

    Many entities in dermatology may not be perfectly captured by any of the levels described.

    “while there are many entities in dermatology that may not be perfectly captured by any of the levels described.”
5 of 5

Claims other papers make about this one

Each is checked against this paper’s own text: does it say what the citing paper says it does?

Self-check

Percentages, sums and reported differences re-computed from the paper’s own numbers.

Each contradiction between two passages listed here was confirmed by an independent check.

  • Definition of stable chronic illness contradicts itself

    Minor

    The table defines a stable chronic illness as one that is not at the patient's treatment goal, then says a patient who is not at that goal is not stable.

1 of 1

Cites

No references could be resolved yet.

Research works printed but not linked: 1

  1. [1]1. American Medical Association. CPT ® Evaluation and management (E/M) office or other outpatient (99202-99215) and prolonged services (99354, 99355, 99356, 99417) code and guideline changes. Accessed May 14, 2021. https://www.ama-assn.org/system/files/2019-06 /cpt-office-prolonged-svs-code-changes.pdf

Cited by

Sorted by citations

Authors
Flamm, A.
Affiliations
Pennsylvania State University (US)
Corresponding author
Flamm, Alexandra
Venue
Cutis
Published
2021-06
Volume
107
Issue
6
Pages
301-325
ISSN
0011-4162 (ISSN-L)
OpenAlex
W3184619883
Cited by
5
References
0
Citations by year
2026: 1 · 2024: 2 · 2023: 1 · 2022: 1
FWCI
0.87
Type
journal article
Language
en
Open access
Locations
  • Cutis (publishedVersion)
  • PubMed (publishedVersion)
Topics
  • Health Sciences › Health Professions › Health Information Management › Medical Coding and Health Information
  • Social Sciences › Economics, Econometrics and Finance › Economics and Econometrics › Healthcare Policy and Management
  • Health Sciences › Health Professions › Medical Terminology › Medical Research and Practices
Keywords
evaluation and management codes, clinical decision-making, office visits, outpatient visits, clinical documentation, medical billing, American Medical Association, Centers for Medicare and Medicaid Services
MeSH terms
Aged, Documentation, Medicare, Humans, United States, Centers for Medicare and Medicaid Services, U.S.

About these checks

Registry, retraction, Cites and statistics results are computed, not judged, with one exception: a printed reference that no index lists is read once by a model before it counts as a citation error. Claims are extracted by a model and kept only when their quote appears verbatim in the text; each cited source is then checked, with a model’s help, for whether it says what the claim relies on. Those verdicts can be wrong — read the claim’s quote and the cited source before relying on one.

Claims read by deepseek-v4.1-flash under definition version 3 (extract-v3) on 2026-10-11.

Classified by jev-1.13-20260917 (gold-guideline-v0.2) on 2026-10-11.

Statistics and arithmetic are recomputed, not judged.

Confidence bands are shown only for fields calibrated on our annotated test set. None is calibrated yet, so no band is shown.

What counts as a claim ›How we measure confidence ›How we check this ›

Are you an author, or do you see a problem with this page? Request a review