The new year has certainly brought more than its share of coding updates. Here’s a quick round-up of what to know for 2021.

2021 E/M coding updates

After many years of deliberation, 2021 E/M coding has been updated to be based on either medical decision making (MDM) or time as the main criteria for determining the level of service. The extent of history and physical examination are no longer used as elements to determine accurate coding. Still, providers are expected to rely on their professional expertise to decide the relevant information required and document it in the patient history. Outpatient E/M visits will no longer use the 1995 or 1997 guidelines.

Level 1 new patient E/M code 99201 has been eliminated, and 99211 is considered a straightforward diagnosis and treatment – to the extent that the presence of a qualified health professional may not be necessary.

The rest of the levels have been shifted to help make MDM determinations more straightforward:

CodeLevel of MDM
99202/99212Straightforward with minor problems and minimal complexity and risk of morbidity
99203/99213Low with minor problems, limited complexity, and low morbidity risk
99204-99214Moderate with acute or chronic illness, review of data necessary for diagnosis and/or treatment, and moderate morbidity risk
99205/99215High with more than one chronic disease with severe exacerbation or progression or acute illness or injury that poses a threat to life or bodily function, an extensive review of data necessary for diagnosis and/or treatment, and high risk of morbidity from additional diagnostic testing or treatment

When time is used as the main element for determining E/M levels, it is critical that exact timekeeping is recorded in the patient record. Time requirements for 2021 E/M coding are as follows:

LevelNew Patient (minutes)Established Patient (minutes)

Codes that can be used to indicate prolonged level 5 new and established patient E/M visits, as well as codes to show increased complexity for level 5 visits, have also been added for 2021.

New COVID vaccine codes are tied to the type of vaccine

To track distribution and aid in analysis, codes have been added to indicate vaccine types and vaccine administration:

CodeDescriptorAdmin CodesManufacturer
91300mRNA-LNP, spike proteinDose 1 – 0001ADose 2 – 0002APfizer
91301mRNA-LP, spike proteinDose 1 – 0011ADose 2 – 0012AModerna
91302DNA, spike protein, Oxford 1 vectorDose 1 – 0021ADose 2 – 0022AAstraZeneca
91303DNA, spike protein, adenovirus vectorSingle dose – 0031AJanssen

New COVID vaccine codes will be added as vaccines are approved for use. Check the AMA website for information.

Also note:

CPT 99072: additional supplies and staff time to mitigate transmission of respiratory infection disease

There are many more changes included in the 2021 CPT code set

According to the AMA, there were 329 changes to 2021 CPT coding – including 206 new codes, 54 deleted codes, and 69 revised codes. Many new codes are tied with new technology. For example, CPT 92229 was added for retinal imaging with automated point-of-care (for primary care settings). CPT range 93241-93248 was added to include continuous cardiac monitoring and detection via a patch worn by patients.

There will be more CPT coding updates in 2021

Keeping track of CPT coding changes while managing a healthcare organization impacted by the COVID pandemic may be challenging in the year ahead. In addition to regularly monitoring CMS and AMA updates, MACs and payers will be publishing their guidance about coding and proving medical necessity. Staying on top of the latest changes will be critical to your practice’s financial health – using the right partner for practice management software and billing makes it easy. Contact Virtual Revenue Solutions today at (412) 424-2260 or visit to learn how we can help keep you informed of coding changes, optimize MIPS, streamline claims, and maximize revenue.