What documentation is required to support a higher-level E/M code during an audit?

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To support a higher-level Evaluation and Management (E/M) code during an audit, detailed and accurate documentation is essential. The documentation must clearly justify the complexity and medical necessity of the service provided. Here's what should be included:

📋 Key Components of E/M Documentation

For office and outpatient visits (based on 2021+ guidelines):

1. Medical Decision Making (MDM)

This is the most critical factor for higher-level codes (e.g., 99214, 99215). MDM is based on:

  • Number and complexity of problems addressed

  • Amount and/or complexity of data reviewed and analyzed (e.g., labs, imaging, records, discussions with other providers)

  • Risk of complications or morbidity/mortality related to patient management

Example: Managing multiple chronic conditions with medication changes and reviewing external records supports a higher code.

2. Time (if billing based on time)

  • Document total time spent on the date of the encounter, including:

    • Reviewing records

    • Counseling the patient

    • Documenting the visit

    • Coordinating care

  • Must match the time range defined for the code (e.g., 40–54 minutes for 99215 in 2024).

3. Medical Necessity

  • Services provided must be reasonable and necessary based on the patient's condition.

  • Overdocumentation without medical necessity will not support a higher code.

Best Practices

  • Avoid vague language (e.g., "doing well"); be specific.

  • Clearly document assessments, decisions, and follow-up plans.

  • Include support for any data reviewed or coordination of care performed.

Accurate, thorough, and medically justified documentation is essential to defend higher-level E/M codes in an audit.

Read More

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