2021 EM – Prolonged Services

In this blog series we are going to do a deep dive into the 2021 E/M Changes. During the series I will be referring to the official guidelines from the AMA. Click the link below to download a copy.


In the last post we talked about how time is going to change the way you level your office/outpatient visits come 2021. Today we are going to dig into how prolonged services will change as well.

New Prolonged Service Code

If you want an early Christmas present click on the link above and go to page 9. Starting from page 9 until the end of the document is a preview of of the 2021 CPT-4 code book. If you are as big of a coding geek as I am you will be able to imagine how much my dorky coder heart swooned when I saw an actual preview of the 2021 CPT book in this document. But I digress. If you will refer to the last two pages, you will see that the AMA has created a brand new CPT code to report prolonged service codes. That code is 99XXX. Yep weird huh? Below are some guidance on how you will use 99XXX in 2021.

Report 99XXX with 99205 and 99215 only.

The guidance in the parenthesis tells us that we can only report 99XXX with EM codes 99205 and 99215. Do not report 99XXX with any other codes.

Do Not Report 99XXX for Less Than 15 Minutes

The guidance in parenthesis also instructs us to not report prolonged services for less than 15 mins. In those cases report only 99205 or 99215.

Prolonged Service Time Table

The AMA created the handy table below to make it easy to report office/outpatient prolonged services.

AMA CPT 2021

I would like to point out a bonus Christmas present. Notice on the table it states that if you document 75-89 minutes for a new patient you can report 99205 with 99XXX x 1 unit. Well that is very interesting since the time range (see table below) for 99205 will be 60-74 minutes. Let that sink in. The AMA is saying that if you 75 minutes with a new patient you can bill 99205 and also 1 unit of 99XXX. That is literally only one minute more than the time range for the code 60-74 minutes. You are welcome! Note that the same is true with established patient visits. If you document 55 minutes with an established patient you get to bill 99215 plus 99XXX x 1.

CPT-4 CodeTime Range

Before you celebrate too much let’s ask the most important question. Will CMS follow suit with their time calculations? Don’t bet on it. According to the CMS Proposed rule that was released on 8/17/2020 they are not going to be following the AMA’s lead on this. If you compare the CMS tables below to the AMA tables at the beginning of this post you will see there is a difference in the way the CMS sees the threshold times for 99XXX. Notice that for 99205 x 1 unit of 99XXX the time is 75-89 minutes for the AMA but it is 89-103 minutes for CMS. Since this is the “proposed rule” it is subject to change. Once the final rule comes out in November we will know for sure.

CMS Proposed Rule https://www.govinfo.gov/content/pkg/FR-2020-08-17/pdf/2020-17127.pdf
CMS Propose Rule https://www.govinfo.gov/content/pkg/FR-2020-08-17/pdf/2020-17127.pdf

The next post will be all about medical decision making (MDM). We will talk about how it is changing for 2021 and how it will be used to level an office visit in 2021.

2021 EM Changes – Time

In this blog series we are going to do a deep dive into the 2021 E/M Changes. During the series I will be referring to the official guidelines from the AMA. Click the link below to download a copy.


In today’s post I am going to address how time will be used to level services in 2021.

Counseling and/or Coordination of Care Caveat Goes Away

Currently, you have to document that you spent greater than 50% of your visit in counseling and/or coordination of care in order to level your office service based on time. The 2021 changes will allow you to report codes 99202-99215 based on the total time spent regardless of counseling or coordination of care.

“Time may be used to select a code level in office or other outpatient services whether or not counseling and/or coordination of care dominates the service.”


Activities You Can Count Towards Your Time

You are going to be pleasantly surprised when you see what activities you will be able to count toward your total time. Keep in mind though that the time for these activities only count if they are performed on the date of the service. You cannot count time spent prior to or after a visit. To properly document your time you need to document the total time spent and then detail the activities that you performed for the visit.

  • Preparing to see the patient (ie, reviewing tests)
  • Obtaining and/or reviewing separately obtained history
  • Performing a medically appropriate exam
  • Counseling and educating the patient/family/caregiver
  • Ordering medications, test, or procedures
  • Referring and communicating with other health care providers
  • Documenting clinical information in the EHR or medical record
  • Independently interpreting result (not separately reported)
  • Communicating results to patient/family/caregiver
  • Care coordination (not separately reported)

Do Not Count Time Spent on Separately Reported Activities

You may have noticed that they keep mentioning (not separately reported). What they mean is if you are going to bill it separately do not count the time for that as EM time. For example, if you do an EKG on a patient and bill for it, do not also count the time it took you to do the EKG as part of your EM. Don’t double dip. It is as simple as that.

Time Thresholds Change in 2021

Now let’s take a peak at how the time thresholds will look in 2021.

CPT CodeCurrent Time2021 Time

In the next blog post we will discuss how these time changes will affect prolonged services.