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Ask a Rev Cycle Expert: E/M Codes for Telephone Encounters?


Now that we're in 2021, for E/M codes, now pre-visit planning, actual time with the patient, care coordination can be counted into the total time to bill. However, does this also ring true for the Telephone E/M codes? For everything we can count time for 99201-99205 and 99212-99215, can we also count the same things for 99441-99443, or can we only strictly count the time spent talking to the patient for 99441-99443?


The 2021 Current Procedural Terminology (CPT®) updates to the evaluation and management (E/M) codes only affects the Office or Other Outpatient Services codes 99202-99215 at this time. The new guidelines do not yet affect the other E/M services, such as the Non-Face-to-Face Services / Telephone services 99441-99443. Of note, CPT® codes 99441-99443 are reportable on professional claims, while facilities may report CPT® codes 98966-98968 for clinical staff time.

At this time, only time spent in medical discussion with the patient, parent or guardian may be included in the time calculations for CPT® codes 99441-99443. During the COVID-19 public health emergency (PHE), the Centers for Medicare & Medicaid Services (CMS) has relaxed the “established patient” criterion and will allow the use of these codes for new patients.

Disclaimer: This information was current at the time of its publishing and is designed to provide accurate information in regard to the subject matter covered. Vitalware does not accept any responsibility or liability with regard to any errors, omissions, misuses, or misinterpretation by the reader. It is not intended to take the place of either the written policies or regulations. We encourage you to review the specific regulations and other interpretive materials as necessary. All CPT® codes are trademarked by the American Medical Association (AMA) and all revenue codes are copyrighted by the American Hospital Association (AHA).