What You Need to Know About CMS Changes to the Physician Fee Schedule for 2021

by Sunil Verma, MD, MBA •

The criteria used to determine total time spent in the visit now include all time spent on the day of the encounter.

If a physician and advanced practice provider (APP; i.e., nurse practitioner or physician assistant) perform a shared visit, the time that each provider spends separately can be counted and added together to determine the level of service for the visit. Time that the physician and APP spend together can be counted only once, however, and time that a resident physician spends with a patient alone does not count toward the total time. It’s also important to note that time spent during procedures billed through separate CPT codes, such as flexible laryngoscopy, does not count toward total time.

Medical Decision Making (MDM). The complexity of MDM is based on meeting elements from two of the three following categories (see the table on page 18 for more detailed information):

  1. Number and complexity of problems addressed during the encounter;
  2. Amount and/or complexity of data reviewed and analyzed; and
  3. Risk of complications and/or morbidity or mortality of patient management.

For otolaryngologists, MDM complexity is most often established through documentation of information from elements 1 and 3. It’s important for providers to separately list each problem along with its management. As always, detailing what information is reviewed and outcomes of patient management are vital not only for risk management but also for billing and coding.

Disclaimer note: Please check with your own compliance and risk office as per their interpretation of the CMS rules.

Dr. Verma is an assistant dean of clinical affairs at UC Irvine. He is also the director of the UCI Health Voice and Swallowing Center and the medical director of the department of otolaryngology–head and neck surgery.