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In 2021, the Centers for Medicare and Medicaid Services (CMS) implemented new rules for coding outpatient Evaluation and Management (E&M) encounters. These rules were updated in 2024. Clinicians can use time-based or medical decision making (MDM) based coding for encounters. These rules apply to Medicare payments but have been adopted by most health insurance plans for non-Medicare treatment. Many but not all workers’ compensation (WC) insurance providers have also adopted the new rules.
ACOEM offers this tip sheet to assist providers of WC care in appropriately documenting care using the current coding model. Recognizing that WC care differs from personal medical care in several respects, ACOEM proposes some additions to the documentation examples for time-based coding offered by CMS. ACOEM believes that time-based coding, with appropriate documentation in the patient’s health record, may be a better alternative than MDM-based coding for WC encounters, because it provides the most flexibility.