Beyond Coding & Documentation: The Impact of the 2021 E/M Changes, Part 4

Welcome to Part 4 of our ongoing series, 2021 E/M Changes: The Impact Beyond Coding & Documentation. In this series, we aim to cover the impact the 2021 E/M guidelines changes are having across organizations. In this, the fourth and final part of the series, we’re turning our focus to how Work-flows might have been impacted, then wrapping up with some final takeaways. Let’s dive right in…

Work-flow Impact

Who do the changes in the E/M guidelines predominantly affect in the organization? I think without a doubt, the most impacted team members are providers. That said, we can’t minimize just how much the back office clinical staff, coders, and auditors have also been impacted. While these changes are, in part, aimed at creating a more patient-centric environment, by reducing documentation requirements, they also indirectly affect work-flows throughout much of your organization.

In an E/M Revisions study, the AMA estimates that over two minutes can be saved per visit with the implementation of the new E/M guidelines and the reduction of documentation requirements. However, effective training of the new guidelines, system optimization through updates to documentation templates, and change in provider documentation habits and practices is necessary to achieve this. Providers can choose each visit to bill based on what is most advantageous, time or MDM. If they choose to bill based on time, that time includes not just time spent seeing the patient but also time spent reviewing diagnostic tests, coordinating care with other providers, ordering labs or other tests, and dictating, among other things. The code billed can only reflect the time spent on that day. If your organization has providers whose work-flow is to perform some of these functions on different days, you may want to re-evaluate their processes.

Does time saved with the decrease in documentation create an opportunity for providers to see more patients? This will vary from provider to provider, and will remain a work-in-progress to identify what works best for your organization.

The back office work-flow for medical assistants and nurses may change some if the provider is billing based on time. Information that may typically be gathered on the day of the appointment, such as labs, diagnostics, and medical records may need to be obtained the day prior, or several days prior, to ensure the provider has time to review on the date of service to get adequate credit for time.

The potential for under-coding should now, more than ever, be on your radar. If your providers are doing their own coding, initially this may mean more intensive review of documentation to ensure code accuracy. And coders and auditors may need to allow for change in their work-flow as well. It is anticipated more time will be spent reviewing the documentation through the lens of the new guidelines. As a result, we’re finding that many organizations are performing smaller, more frequent audits to validate the accuracy of coding, with education of the providers and coding staff. Whether performed internally, or by a third-party vendor, this may be something your organization wants to consider.

Key Take-Aways

    1. Knowledge is power, and it is safe to assume that we have not seen the last of the changes to the E/M guidelines. The question still lingers what guideline revisions are expected for inpatient E/M services. By monitoring how the outpatient E/M guideline changes have affected your organization, you stand to gain a lot by understanding how these changes affect revenue and your work-flows.
    2. Assess where your EHR / RCM system is at with the new CPT codes and changes to logic for both code selection and claim edits.
    3. Keep a close eye on the productivity of your providers and coders. AAPC Audit Services is conducting a time study with our own team of auditors to evaluate the effect on their productivity when applying the new guidelines. It is far too early to release results of that study, but from what we have seen industry wide, these changes are extremely difficult to implement, and it is taking more time–at least initially–to code and audit these services as we build our muscle memory.
    4. Review your benchmarks and key performance indicators closely. Share the information within the organization so everyone can understand the impact they have on the whole process.
    5. Lastly, we recommend that you incorporate quick check audits, whether that is with a third- party vendor, or internally. These are not full-scope audits that include all procedure codes, modifiers, or ICD-10 codes. The focus is on the understanding and implementation of the new guidelines. It will be far more advantageous to find out early on that you have issues, than it would be to find those issues several months down the road - after your revenue has been affected, or bad patterns have been established that require correction.


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